Court filing
Exhibit 2 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 611-4, S.D. Cal. No. 3:21-md-02992)
Filed January 8, 2026 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 | 2026-01-08 |
U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 611-4 · 2026-01-08 · Docket on CourtListener
Full text
Exhibit 2
Case 3:21-md-02992-GPC-MSB Document 611-4 Filed 01/08/26 PageID.43368
Page 1 of 19
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
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SAN DIEGO DIVISION
3
Civil Action No. 21-MD-02992-GPC-MSB
____________________________________________________________
4
IN RE: BANK OF AMERICA CALIFORNIA
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UNEMPLOYMENT BENEFITS LITIGATION
____________________________________________________________
6
7
VIDEO DEPOSITION OF CHLOE NOEL EAST, Ph.D.
8
May 15, 2025
____________________________________________________________
9
10
APPEARANCES:
ON BEHALF OF THE PLAINTIFFS:
11
CAROLINE HUNSICKER, ESQ.
CONNIE K. CHAN, ESQ. (via remote)
12
Altshuler Berzon LLP
177 Post Street, Suite 300
13
San Francisco, California 94108
Phone: 415-421-7151
14
Email: chunsicker@altshulerberzon.com
Email: cchan@altber.com
15
16
and
JOSHUA B. SWIGART, ESQ. (via remote)
17
ILANA PLATKIEWICZ, ESQ. (via remote)
Swigart Law Group, APC
18
2221 Camino Del Rio S, Suite 308
San Diego, California 92108
19
Phone: 866-219-3343
Email: josh@swigartlawgroup.com
20
Email: ilana@swigartlawgroup.com
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22
23
24
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APPEARANCES (cont.):
2
ON BEHALF OF THE PLAINTIFFS (cont.):
BRIAN DANITZ, ESQ. (via remote)
3
Cotchett, Pitre & McCarthy, LLP
840 Malcolm Road, Suite 200
4
Burlingame, California 94010
Phone: 650-697-6000
5
Email: bdanitz@cpmlegal.com
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and
7
COLIN M. JONES, ESQ. (via remote)
Wilshire Law Firm PLC
8
3055 Wilshire Boulevard, 12th Floor
Los Angeles, California 90010
9
Phone: 213-381-9988
Email: colin@wilshirelawfirm.com
10
11
ON BEHALF OF THE DEFENDANT, BANK OF AMERICA:
LAURA G. BRYS, ESQ.
12
KELSI QUARLES, ESQ. (via remote)
Goodwin Procter LLP
13
601 South Figueroa Street, Suite 4100
Los Angeles, California 90017
14
Phone: 213-426-2500
Email: lbrys@goodwinlaw.com
15
Email: kquarles@goodwinlaw.com
16
and
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ETHAN SHUCHART, ESQ.
Goodwin Procter LLP
18
100 Northern Avenue
Boston, Massachusetts 02210
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Phone: 917-229-7837
Email: eshuchart@goodwinlaw.com
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Also Present: Dustin Brown, videographer
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PURSUANT TO WRITTEN NOTICE and the appropriate
2
rules of civil procedure, the video deposition of
3
CHLOE NOEL EAST, Ph.D., called for examination by the
4
Defendant, Bank of America, was taken at Courtyard Denver
5
Airport, 6901 Tower Road, Denver, Colorado, commencing at
6
9:05 AM on May 15, 2025, before Deanna Baysinger, a Notary
7
Public and Registered Professional Reporter in and for the
8
State of Colorado.
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10
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I N D E X
2
EXAMINATION: PAGE
3
By Ms. Brys 7, 178
By Ms. Hunsicker 171
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5
6
7
EXHIBITS: PAGE
8
Exhibit 1 Defendant Bank of America, N.A.'s 9
9
Third Amended Notice of Deposition to
Plaintiffs' Expert Chloe East
10
Exhibit 2 Expert Report of Chloe N. East dated 23
11
3/4/25
12
Exhibit 3 Plaintiffs' Supplemental Expert 24
Designation
13
Exhibit 4 Plaintiffs' Rebuttal Expert 25
14
Designations
15
Exhibit 5 Expert Report of Victor Stango dated 25
10/24/24
16
Exhibit 6 Expert Report of Victor Stango dated 26
17
4/4/25
18
Exhibit 7 Expert Report of Professor Justin 27
McCrary, Ph.D., dated 4/4/25
19
Exhibit 8 Expert Report of Greg J. Regan, 37
20
CPA/CFF, CFE dated 3/4/25
21
Exhibit 9 Article titled Spending and 63
Job-Finding Impacts of Expanded
22
Unemployment Benefits: Evidence from
Administrative Micro Data by Peter
23
Ganong, Fiona Greig, Pascal Noel,
Daniel M. Sullivan, and Joseph Vavra
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25
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EXHIBITS (cont.): PAGE
2
Exhibit 10 Article titled U.S. Unemployment 68
3
Insurance Replacement Rates During the
Pandemic by Peter Ganong, Pascal Noel,
4
and Joseph Vavra
5
Exhibit 11 Article titled Consumer Spending 68
during Unemployment Positive and
6
Normative Implications by Peter Ganong
and Pascal Noel
7
Exhibit 12 Discussion Paper titled Impacts of the 84
8
COVID-19 Pandemic and the CARES Act on
Earnings and Inequality dated August
9
2020
10
Exhibit 13 NBER Working Paper Series, How Did 86
U.S. Consumers Use Their Stimulus
11
Payments? Dated August 2020
12
Exhibit 14 Article titled U.S. Economic Recovery 90
in the Wake of COVID-19: Successes
13
and Challenges by Labonte and
Weinstock
14
Exhibit 15 Article titled Reexamining the 92
15
Consumption Smoothing Benefits of
Unemployment Insurance by East and
16
Kuka
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Exhibit 16 Paper titled The Safety Net and Job 98
Loss: How Much Insurance Do Public
18
Programs Provide? dated 8/29/24
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Exhibit 17 Expert Report of David I. Levine dated 162
3/4/25
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21
22
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24
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P R O C E E D I N G S
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THE VIDEOGRAPHER: Good morning. We are 09:04AM
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on record at 9:05 AM on May 15, 2025. This is the video 09:05AM
4
recorded deposition of Chloe East. 09:05AM
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My name is Dustin Brown here with our 09:05AM
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court reporter Deanna Baysinger. 09:05AM
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This deposition is being held at 09:05AM
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6901 Tower Road in Denver, Colorado. 09:05AM
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Caption of the case is Bank of America 09:05AM
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California Unemployment Litigation. 09:05AM
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Please note that audio and video recording 09:05AM
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will take place unless all parties agree to go off 09:05AM
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record. 09:05AM
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Counsel will now introduce themselves 09:05AM
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beginning with the noticing attorney. 09:05AM
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Thank you. 09:05AM
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MS. BRYS: Good morning. I'm Laura Brys 09:05AM
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of Goodwin Procter, counsel for Defendant, Bank of 09:05AM
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America. 09:05AM
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MR. SHUCHART: Good morning. Ethan 09:05AM
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Shuchart also with Goodwin Procter on behalf of 09:06AM
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Defendant, Bank of America. 09:06AM
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MS. HUNSICKER: I'm Caroline Hunsicker 09:06AM
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with Altshuler Berzon on behalf of Plaintiffs. 09:06AM
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MS. CHAN: Good morning. Connie Chan of 09:06AM
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Altshuler Berzon also on behalf of Plaintiffs. 09:06AM
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CHLOE NOEL EAST, Ph.D., 09:06AM
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called as a witness, having been first duly sworn, was 09:06AM
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examined and testified as follows: 09:06AM
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EXAMINATION 09:06AM
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BY MS. BRYS: 09:06AM
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Q. Good morning, Ms. East. Can you please 09:06AM
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state your full name for the record. 09:06AM
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A. Yes. My name is Chloe Noel East. 09:06AM
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Q. Are you represented by counsel here today? 09:06AM
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A. Yes. 09:06AM
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Q. Okay. Have you ever been deposed before? 09:06AM
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A. No. 09:06AM
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Q. How many times have you been retained as an 09:06AM
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expert? 09:06AM
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A. This is the first time. 09:06AM
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Q. And who retained you in this case? 09:06AM
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A. Plaintiffs' counsel. 09:06AM
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Q. So just some ground rules for today's 09:06AM
20
deposition since you have not been deposed before. 09:06AM
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I'm going to try to speak as slowly as I 09:07AM
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can if you can also try to speak slowly so the court 09:07AM
23
reporter can take down what's being said. 09:07AM
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Also, all answers need to be verbal. So I 09:07AM
25
see that you're acknowledging by nodding your head, but 09:07AM
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A. Sorry. I'm still not sure I'm 11:17AM
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understanding. Are you referring to the UI supplement or 11:17AM
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the stimulus or -- 11:17AM
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Q. (By Ms. Brys) Correct. I'm referring to 11:17AM
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the stimulus check. 11:17AM
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A. Okay. You are referring to the stimulus 11:17AM
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check. 11:17AM
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Q. Correct. 11:17AM
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A. So most people in the U.S., although not 11:17AM
10
everybody in the U.S., received a stimulus check in 11:17AM
11
April 2020 and that would include individuals who were 11:17AM
12
unemployed and/or receiving UI benefits. 11:17AM
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Q. And would that increase the recipient's -- 11:17AM
14
the check recipient's liquidity? 11:17AM
15
MS. HUNSICKER: Objection. Incomplete 11:18AM
16
hypothetical. 11:18AM
17
A. It would increase the recipient's 11:18AM
18
liquidity. 11:18AM
19
However, the evidence that I've reviewed 11:18AM
20
suggests that increase is not very large and that 11:18AM
21
households are still in a difficult financial situation. 11:18AM
22
Q. (By Ms. Brys) And what evidence did you 11:18AM
23
review that supports that opinion? 11:18AM
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A. The evidence that I reviewed includes the 11:18AM
25
statistical analyses that I performed for my report as 11:18AM
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well as the 2024 Peter Ganong, et al. paper. 11:18AM
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Q. Okay. And then in addition to the CARES 11:18AM
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Act, are you familiar with the Pandemic Unemployment 11:19AM
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Assistance Program? 11:19AM
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A. Yes. 11:19AM
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Q. What is that program? 11:19AM
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A. I believe, if I'm remembering correctly, 11:19AM
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this is the $300 supplement that was issued beginning in 11:19AM
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January 2021. 11:19AM
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Q. And to the extent it's your understanding 11:19AM
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that it is an additional supplement that was issued, would 11:19AM
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that include -- would that increase a -- would that check 11:19AM
13
increase a recipient's liquidity? 11:19AM
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A. Yes, it would increase the recipient's 11:19AM
15
liquidity although, again, the evidence that I reviewed 11:19AM
16
suggests that it's not drastically changing households' 11:19AM
17
finances and that they're still in a difficult financial 11:20AM
18
situation. 11:20AM
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Q. Likewise, are you familiar with the Federal 11:20AM
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Pandemic Unemployment Compensation Program? 11:20AM
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A. I am forgetting the details of that one. 11:20AM
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Q. I'm representing that it initially provided 11:20AM
23
an additional 600 per week. 11:20AM
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To the extent I make that representation 11:20AM
25
and UI benefits supplements for up to four months, does 11:20AM
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that refresh your recollection as to that program? 11:20AM
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A. Yes. Thank you. 11:20AM
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Q. Is it your understanding that that program 11:20AM
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would increase the check recipient's liquidity? 11:20AM
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A. Yes. This increase would increase the UI 11:20AM
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recipient's liquidity. 11:20AM
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And again, all the statistical analyses 11:20AM
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that I've done and the literature that I've reviewed 11:20AM
9
suggests that households still remain in a difficult 11:21AM
10
financial situation overall. 11:21AM
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Q. Likewise, are you aware of the Pandemic 11:21AM
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Emergency Unemployment Compensation Program? 11:21AM
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A. I'm forgetting the -- the details of that 11:21AM
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one as well. If you could remind me, please. 11:21AM
15
Q. If I could represent to you that it 11:21AM
16
provided an additional 13 weeks of UI benefits between 11:21AM
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March 29, 2020, and December 26, 2020, and then it was 11:21AM
18
subsequently reinstated, does that refresh your 11:21AM
19
recollection as to additional benefits that were provided 11:21AM
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under this program? 11:21AM
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A. Yes. Thank you. 11:21AM
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Q. Is it your understanding as to whether that 11:21AM
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would, in fact, increase the recipients of that program's 11:21AM
24
liquidity? 11:21AM
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MS. HUNSICKER: Objection. Vague. 11:21AM
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A. Relative to not having any unemployment 11:21AM
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insurance benefits, having more unemployment insurance 11:22AM
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benefits would increase the household's liquidity. 11:22AM
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Although again, I did not see any evidence of big changes 11:22AM
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in household finances and households are still in a 11:22AM
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difficult financial situation. 11:22AM
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Q. (By Ms. Brys) Are you aware of the 11:22AM
8
COVID-Related Tax Relief Act of 2020? 11:22AM
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A. I'm forgetting the details of that one. 11:22AM
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Q. To clarify, it provided -- does it refresh 11:22AM
11
your recollection if I state that it provided an 11:22AM
12
additional $600 for eligible individuals and up to $600 11:22AM
13
for qualifying children under the age of 17? Does that 11:22AM
14
refresh your recollection? 11:22AM
15
A. Yes, it does. 11:22AM
16
Can I ask a follow-up question? Can you 11:22AM
17
remind me of the timing of that one? 11:22AM
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Q. The date of that one. Plot twist. Hold on 11:22AM
19
a second. January 2021. 11:22AM
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A. Okay. Perfect. 11:23AM
21
Q. I believe it was enacted in late December 11:23AM
22
2020. 11:23AM
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A. Thank you. That does refresh my memory. 11:23AM
24
Q. And in your opinion, would recipients of 11:23AM
25
those additional funds, would that increase their 11:23AM
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liquidity? 11:23AM
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A. Yes, that would increase their liquidity. 11:23AM
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Although all the data that I analyzed and 11:23AM
4
the literature that I reviewed suggests that it doesn't 11:23AM
5
increase their liquidity by enough to get them out of 11:23AM
6
their difficult financial situation. 11:23AM
7
Q. Are you also familiar with the American 11:23AM
8
Rescue Plan Act of 2021? 11:23AM
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A. Yes. 11:23AM
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Q. So would it be accurate to say that it 11:23AM
11
provided payments of up to $1400 to eligible individuals, 11:23AM
12
$2800 for married couples filing jointly, and $1400 for 11:24AM
13
qualifying dependents? 11:24AM
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A. I don't remember those numbers off the top 11:24AM
15
of my head but that sounds reasonable to me. 11:24AM
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Q. And would those additional funds that were 11:24AM
17
provided to those recipients, would that increase their 11:24AM
18
liquidity? 11:24AM
19
A. It would increase their liquidity. 11:24AM
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Although, the data that I reviewed and the 11:24AM
21
literature that I reviewed suggests that it would not 11:24AM
22
increase their liquidity to a point to get them out of 11:24AM
23
their difficult financial situation. 11:24AM
24
Q. Are you also familiar with the Golden State 11:24AM
25
Stimulus Program? 11:24AM
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A. I do not remember the details of that one. 11:24AM
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Q. If I represented to you that California 11:24AM
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offered two rounds of stimulus payments to low-income 11:24AM
4
individuals during the pandemic, does that refresh your 11:24AM
5
recollection? 11:24AM
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A. Yes. 11:24AM
7
Q. Would recipients of those additional funds, 11:24AM
8
would that increase their liquidity through receipt of 11:25AM
9
those funds? 11:25AM
10
A. Yes. 11:25AM
11
Although all the data that I analyzed and 11:25AM
12
the literature that I reviewed suggests that households 11:25AM
13
still remain in a difficult financial situation. 11:25AM
14
Q. And are you familiar with the fact that 11:25AM
15
California had a statewide moratoria on disconnection of 11:25AM
16
essential services for nonpayment and waiver of fees for 11:25AM
17
late payments during the COVID era? 11:25AM
18
A. Yes. 11:25AM
19
Q. What impact would that have on an 11:25AM
20
individual household's liquidity? 11:25AM
21
A. Hypothetically, that program could reduce 11:25AM
22
household expenses. 11:25AM
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Although, all the data that I reviewed and 11:25AM
24
the literature that I've reviewed suggests that 11:25AM
25
households remain in a difficult financial situation. 11:25AM
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A. I read the beginning of it but did not 11:54AM
2
read the entire thing in detail. 11:54AM
3
Q. To your knowledge during the pandemic, were 11:54AM
4
spending rates the same as they were for U.S. households 11:54AM
5
before the pandemic? 11:54AM
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MS. HUNSICKER: Objection. Vague. 11:54AM
7
A. What do you mean by "spending rates"? 11:54AM
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Q. (By Ms. Brys) Was there an increase in 11:54AM
9
savings by U.S. households during the pandemic? 11:54AM
10
A. For households as a whole, yes, my 11:54AM
11
understanding is that there was an increase in savings 11:55AM
12
rates. 11:55AM
13
Q. Do you have any understanding as to whether 11:55AM
14
there was a change in saving rates for households that 11:55AM
15
collected UI benefits? 11:55AM
16
A. I -- I'm just thinking through the 11:55AM
17
different pieces of evidence. 11:55AM
18
In my own analysis of the SIPP data, I 11:55AM
19
investigated if there were big changes in net liquid 11:55AM
20
wealth of UI recipients over the COVID pandemic era and 11:55AM
21
did not find big changes in net liquid wealth. 11:55AM
22
Q. Okay. And what do you mean by net liquid 11:55AM
23
wealth? 11:56AM
24
A. I mean the measure we were discussing 11:56AM
25
earlier that is the difference between household's liquid 11:56AM
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savings measures and their unsecured debt. 11:56AM
2
Q. So would it be accurate for me to say that 11:56AM
3
based on your analysis of the data, that the savings 11:56AM
4
measures before and after the pandemic for UI household 11:56AM
5
benefits recipients generally remain the same? 11:56AM
6
MS. HUNSICKER: Objection. Misstates 11:56AM
7
testimony. 11:56AM
8
A. That's not quite how I would say it. 11:56AM
9
I would say that the net liquid wealth 11:56AM
10
remains similar right before the pandemic and 2020 and 11:56AM
11
2021. 11:56AM
12
Q. (By Ms. Brys) Okay. So looking at 11:56AM
13
Exhibit 13, Paragraph 2 -- 11:57AM
14
A. Yes. 11:57AM
15
Q. -- so based on your review of this article, 11:57AM
16
does this familiarize you with the fact that survey data 11:57AM
17
indicates that U.S. households reported spending only 11:57AM
18
approximately 40 percent of their first stimulus check 11:57AM
19
with 30 percent being saved and another 30 percent used to 11:58AM
20
pay down debt? 11:58AM
21
A. Yes. 11:58AM
22
Q. Okay. Are you aware that according to the 11:58AM
23
Federal Reserve Bank of New York Survey of Consumer 11:58AM
24
Expectations, respondents reported that they had saved or 11:58AM
25
expected to save 36.4 percent of the first round of 11:58AM
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care. And so this -- applying the credit card interest 02:20PM
2
rate to the full population is a conservative estimate 02:20PM
3
for the many people who have to cut consumption. 02:20PM
4
Q. And then in connection with this opinion, 02:20PM
5
what evidence or data did you rely upon? 02:20PM
6
A. What do you mean "this opinion"? Which 02:20PM
7
opinion? 02:20PM
8
Q. The credit card interest -- the credit 02:20PM
9
interest rate as a conservative measure of the opportunity 02:20PM
10
cost of lost funds. 02:20PM
11
A. For this, I relied on a lot of different 02:20PM
12
things, which is why I'm being a little slow in 02:20PM
13
answering. 02:20PM
14
The literature that I reviewed all shows 02:20PM
15
that people cut consumption when UI benefits are less 02:20PM
16
generous or when UI benefits run out. And the analysis 02:21PM
17
that I did suggests that the most common responses are 02:21PM
18
borrowing on a credit card or some more expensive 02:21PM
19
borrowing or -- I should say the most common responses 02:21PM
20
are borrowing on credit card or cutting consumption, 02:21PM
21
which will be even more expensive. 02:21PM
22
Q. And then you opine in Paragraph 36 that the 02:21PM
23
median recipient had a good credit score. 02:21PM
24
A. Yes. 02:21PM
25
Q. Again, that is using the median to 02:21PM
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represent the entire population because there would be 02:21PM
2
variation in which some would have a higher and some might 02:21PM
3
have a lower credit score. 02:21PM
4
A. Right. So the reason that I chose to use 02:21PM
5
a median is that when we're doing this kind of analysis 02:22PM
6
as economists, we choose a number that is representative 02:22PM
7
of most people in the population rather than focusing on 02:22PM
8
the extremes at either end of the distribution. 02:22PM
9
Q. So to the extent somebody had a credit 02:22PM
10
score of 800, they may have a lower APR. Would that be 02:22PM
11
accurate? 02:22PM
12
MS. HUNSICKER: Objection. Incomplete 02:22PM
13
hypothetical. 02:22PM
14
A. That would be accurate, but that is not 02:22PM
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the most common experience of the group. 02:22PM
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Q. (By Ms. Brys) So in connection with the 02:22PM
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preparation of your report, what is the process you used 02:23PM
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to draft your report in this case? 02:23PM
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MS. HUNSICKER: Objection. Overbroad. 02:23PM
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A. The process that I used was to review the 02:23PM
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literature on unemployment insurance and to conduct my 02:23PM
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own statistical analyses of UI recipients' financial 02:23PM
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conditions. 02:23PM
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Q. (By Ms. Brys) And then would it be 02:23PM
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accurate to say you performed your work for this report in 02:23PM
Page 148
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Case 3:21-md-02992-GPC-MSB Document 611-4 Filed 01/08/26 PageID.43385
Page 18 of 19
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CERTIFICATE OF COURT REPORTER
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I, DEANNA BAYSINGER, a Registered Professional
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Reporter and Notary Public within and for the State of
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Colorado, commissioned to administer oaths, do hereby
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certify that previous to the commencement of the
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examination, the witness was duly sworn by me to testify
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the truth in relation to matters in controversy between
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the said parties; that the said deposition was taken in
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stenotype by me at the time and place aforesaid and was
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thereafter reduced to typewritten form by me; and that
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the foregoing is a true and correct transcript of my
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stenotype notes thereof.
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That I am not an attorney nor counsel nor in
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any way connected with any attorney or counsel for any of
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the parties to said action nor otherwise interested in the
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outcome of this action.
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My commission expires: November 8, 2026.
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19
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<%22389,Signature%>
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DEANNA BAYSINGER
Registered Professional Reporter
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Notary Public, State of Colorado
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Page 182
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