Exhibit PX231 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 634-232, 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. 634-232 · 2026-01-09 · Docket on CourtListener

Full text

PX231 
Case 3:21-md-02992-GPC-MSB     Document 634-232     Filed 01/09/26     PageID.53974 
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Roland Oosthuizen 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA 
SAN DIEGO DIVISION 
IN RE: 
BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT BENEFITS 
LITIGATION 
This Document Relates to All 
Actions 
In re Bank of America Cslifornia 
Unemployment Benefits Litigation 
Case No.: 
21-MD-02992-LAB-MSB 
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VIDEOTAPED DEPOSITION OF ROLAND OOSTHUIZEN 
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Job No. 10136935 
Reported By: 
(Taken by Defendant.) 
March 29, 2024, 9:08 a.m. 
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SUSAN GALLAGHER, CA CSR 14498, CVR-CM 
Transcript produced by computer-aided transcription 
www.aptuaCR.com 
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Roland Oosthuizen 
APPEARANCES 
In re Bank of America California 
Unemployment Benefits Litigation 
For the Plaintiffs: 
LAURA BRYS, ESQ. 
ETHAN SHUCHART, ESQ. 
GOODWIN PROCTER LLP 
601 South Figueroa Street, Suite 4100 
Los Angeles, California 90017 
(213) 426-2584 
lbrys@goodwinlaw.com 
For the Defendant: 
KATHERINE G. BASS, ESQ. 
CONNIE K. CHAN, ESQ. 
ALTSHULER BERZON LLP 
177 Post Street, Suite 300 
San Francisco, California 94108 
(415) 421-7151 
kbass@altshulerberzon.com 
cchan@altshulerberzon.com 
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Also present: 
Karin Swope (appearing via Zoom) 
Vasti Montiel (appearing via Zoom) 
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Fatima Hasenain (appearing via Zoom) 
Virginia Selden Mccorkle (appearing via Zoom) 
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Nicole Kim (appearing via Zoom) 
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Travis Simmons, videographer 
VIDEOTAPED DEPOSITION OF ROLAND OOSTHUIZEN, a witness 
called before SUSAN GALLAGHER, CA CSR 14498, CVR-CM, on Friday 
the 29th of March, 2024, commencing at 9:08 a.m. 
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Roland Oosthuizen 
In re Bank of America California 
Unemployment Benefits Litigation 
PROCEEDINGS 
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THE VIDEOGRAPHER: 
Good morning. 
we are now on the record. 
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Today's date is March 29, 2024, and the time is 9:08 a.m. 
This 
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is the videotaped deposition of Roland Oosthuizen being taken in 
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the matter of Bank of America California Unemployment Benefits 
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Litigation, pending in the us District Court, southern District 
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of California, San Diego Division. 
The case number 
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is 21-MD-02992-LAB-MSB. 
This deposition is taking place at 3200 
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Guasti Road in Ontario, California. 
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My name is Travis Simmons appearing from Aptus Court 
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Reporting located at 401 West A Street, suite 1680, San Diego, 
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California 92101. 
I am the official videographer, and this is 
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the only authorized video recording of the deposition. 
The audio 
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and video recording will take place at all times unless all 
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counsel have agreed to go off. 
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Will counsel please identify yourselves and state whom you 
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represent, starting with the noticing attorney. 
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MS. BRYS: 
Morning. 
My name is Laura Brys. 
I'm with the 
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firm Goodwin Procter and I represent defendant Bank of America. 
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MR. SHUCHART: 
Good morning. 
My name is Ethan Shuchart. 
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I'm with Goodwin Procter and here for the defendant Bank of 
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America. 
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MS. BASS: 
Good morning. 
My name is Katherine Bass. 
I'm 
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with Altshuler Berzon, and I represent the class plaintiffs. 
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Roland Oosthuizen 
In re Bank of America C81ifomia 
Unemployment Benefits Litigation 
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MS. CHAN: 
Connie Chan also with Altshuler Berzon on behalf 
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of the class plaintiffs. 
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ROLAND OOSTHUIZEN, 
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Having been first duly sworn, was examined and testified as 
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follows: 
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EXAMINATION 
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BY MS. BRYS: 
Q 
Good morning, Mr. Oosthuizen. 
A 
Correct. 
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Q 
Thank you. 
I'm going to apologize in advance. 
I will 
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do my best to pronounce your name correctly. 
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Can you please state your full name for the record? 
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A 
My full name is Roland Evan Buster Oosthuizen. 
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Have you ever gone by any other names during your 
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lifetime? 
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A 
No. 
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Have you ever been deposed before? 
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No. 
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Do you understand that your testimony is under oath 
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today as if we were in a court of law? 
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Yes. 
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Q 
Is there any reason why you are unable to give your best 
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and true testimony here today? 
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No. 
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Q 
I'm going to go over a few ground rules with you just 
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Roland Oosthuizen 
MS. BASS: 
Objection. Vague. 
THE WITNESS: 
I don't remember. 
In re Bank of America California 
Unemployment Benefats Litigation 
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BY MS. BRYS: 
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Q 
Did you ever receive your EDD benefits by check? 
A 
I don't remember. 
Q 
Did you know who the card on which you would receive 
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benefits would be issued from? 
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MS. BASS: 
Objection. Vague. 
THE WITNESS: 
As far as which bank? 
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BY MS. BRYS: 
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Q 
Correct. 
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Yes. 
Q 
And which bank was that? 
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BanJc of America. 
if ou could receive our benefits 
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in a form other than b card? 
e. 
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BY MS. BRYS: 
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Q 
Has anyone else ever had access to your EDD account? 
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No. 
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Did you ever access your EDD account on your computer? 
A 
Yes. 
Q 
Did anyone else ever have access to your computer? 
MS. BASS: 
Objection. Vague. 
www.aptusCR.com 
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Roland Oosthuizen 
In re Bank of America califomia 
Unemployment Benefits Litigation 
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Q 
Did you take any notes during this call? 
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Yes. 
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Where did you store those notes? 
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At my morn's house in my room at the time. 
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Do -- did you give those notes to your lawyer to be 
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produced in this case? 
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A 
Yes. 
What ha ened after ou submitted our claim? 
THE WITNESS: 
Shortl after I submitted the claim I 
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received a letter in the mail sa 
claim had been 
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closed and did not rovide an 
lanation as to 
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wh. 
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of that letter? 
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A 
No. 
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ontact 
? 
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A 
Yes. 
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est reconsideration of our claim? 
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MS. BASS: 
ob·ection. Va e. 
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BY MS. BRYS: 
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A 
I don't remember the exact date but I remember it took 
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Roland Oosthuizen 
In re Bank of America Cslifomia 
Unemployment Benefits Litigation 
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reconsideration. 
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MS. BASS: 
ob·ection. Va 
e• lacks foundation. 
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THE 
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BY MS. BRYS: 
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What was the outcome? 
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A 
Eventuall it was a roved after I filed a lawsuit. 
the clai 
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was 
aid? 
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MS. BASS: 
ob·ection. Time frame. 
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THE WITNESS: 
Yes. 
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BY MS. BRYS: 
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A 
Yes. 
Theda after I filed a lawsuit. 
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Q 
How much money did you receive from the bank in 
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connection with your claim? 
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A 
They gave me back the 5,000 that was stolen. 
Q 
So they gave you back the -- strike that. 
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Did you receive any additional payment from Bank of 
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America? 
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MS. BASS: 
Objection. Vague; time frame. 
THE WITNESS: 
Yes . 
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BY MS. BRYS: 
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Q 
When did you receive an additional payment from Bank of 
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Roland Oosthulzen 
In re Bank of America California 
Unemployment Benefits Litigation 
CERTIFICATE OF REPORTER 
---oOo---
I, the undersigned, a Certified Shorthand 
Reporter, Licensed by the State of California, being empowered to 
administer oaths and affirmations, do hereby certify: 
That the foregoing proceedings were taken before 
me at the time and place herein set forth; that any witness in 
the foregoing proceedings, prior to testifying, were placed under 
oath; that a verbatim record of the proceedings was made by me 
using voice stenography, which was thereafter transcribed under 
my direction; further, that the foregoing is an accurate 
transcription thereof. 
I further certify that I'm neither financially 
interested in the action nor a relative or employee of any 
attorney or any of the parties. 
Further, that if the foregoing pertains to the 
original transcript of a deposition in a Federal Case, before 
completion of the proceedings, review of the transcript [ X] was 
] was not requested. 
IN WITNESS WHEREOF, I have this date subscribed my 
name. 
DATED: 
April 15, 2024 
Susan Gallagher, CA CSR 14498, CVR-CM 
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