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Home Court filings In re: Bank of America California Unemployment Benefits Litigation — S.D. Cal., No. 21-md-02992 Bank of America's Motion to Seal Documents Filed in Its Reply in Support of Its Motion for Partial Summary Judgment

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Bank of America's Motion to Seal Documents Filed in Its Reply in Support of Its Motion for Partial Summary Judgment

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Defendant Bank of America, N.A.'s Notice and Motion to Seal Documents Filed in Its Reply in Support of Its Motion for Partial Summary Judgment (ECF 589), filed 02/20/26 as Document 687 in In re: Bank of America California Unemployment Benefits Litigation, Case No. 21-MD-02992-GPC-MSB in the Southern District of California. Under Local Civil Rule 79.2(c), the bank asks to seal certain Brys Declaration exhibits in whole or in part, and references to sealed exhibits in its reply and its responses to plaintiffs' additional facts and evidentiary objections. It argues that compelling reasons apply to summary judgment filings and that the Court largely granted earlier motions to seal material on its fraud detection and prevention policies.

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“Bank of America's Motion to Seal Documents Filed in Its Reply in Support of Its Motion for Partial Summary Judgment.” Original at ecf.casd.uscourts.gov, No. 3:21-md-02992-GPC-MSB, Doc. 687. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-bofa-ca-unemployment-casd-709615/2026-02-20-gov-uscourts-casd-709615-687-0-gov-uscourts-casd-709615-687-0/, SHA-256 69b60cf942cf724372405becef3c4087e8a63f6cd45d3205cd4f7410b6b9d498.

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            Case 3:21-md-02992-GPC-MSB             Document 687    Filed 02/20/26   PageID.59115   Page
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                      1   JAMES W. MCGARRY (pro hac vice)
                          JMcGarry@goodwinlaw.com
                      2   GOODWIN PROCTER LLP
                      3   100 Northern Avenue
                          Boston, MA 02210
                      4   Tel.: +1 617 570 1000
                          Fax: +1 617 523 1231
                      5
                          SABRINA M. ROSE-SMITH (pro hac vice)
                      6   SRoseSmith@goodwinlaw.com
                      7   MATTHEW L. RIFFEE (pro hac vice)
                          MRiffee@goodwinlaw.com
                      8   GOODWIN PROCTER LLP
                          1900 N Street, NW
                      9   Washington, DC 20036
                  10      Tel.: +1 202 346 4000
                          Fax: +1 202 346 4444
                  11
                          Attorneys for Defendant
                  12      BANK OF AMERICA, N.A.
                  13      [ADDITIONAL COUNSEL LISTED IN SIGNATURE BLOCK]
                  14
                                               UNITED STATES DISTRICT COURT
                  15
                                      FOR THE SOUTHERN DISTRICT OF CALIFORNIA
                  16
                                                       SAN DIEGO DIVISION
                  17
                  18      IN RE: BANK OF AMERICA                  Case No. 21-MD-02992-GPC-MSB
                          CALIFORNIA UNEMPLOYMENT
                  19      BENEFITS LITIGATION                     DEFENDANT BANK OF AMERICA,
                                                                  N.A.’S NOTICE AND MOTION TO
                  20                                              SEAL DOCUMENTS FILED IN ITS
                                                                  REPLY IN SUPPORT OF ITS
                  21                                              MOTION FOR PARTIAL SUMMARY
                                                                  JUDGMENT (ECF 589)
                  22
                  23                                              Ctrm:      12A – 12th Floor
                                                                  Judge:     Hon. Gonzalo P. Curiel
                  24
                  25
                  26
                  27
                  28
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY               CASE NO. 3:21-MD-02992-GPC-MSB
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                      1          PLEASE TAKE NOTICE that, pursuant to Local Civil Rule 79.2(c),
                      2   Defendant Bank of America, N.A. (BANA) hereby submits this Notice and Motion
                      3   to Seal (Motion to Seal) certain documents and portions of other documents in
                      4   connection with BANA’s Reply in Support of Its Motion for Partial Summary
                      5   Judgment (Reply). In particular, BANA seeks to seal certain Brys Declaration
                      6   Exhibits1 in their entirety and portions of certain Brys Declaration Exhibits because
                      7   compelling reasons supports sealing of the identified documents, as well as any
                      8   references to those exhibits in BANA’s Reply, BANA’s Response to Plaintiffs’
                      9   Additional Statement of Facts in Opposition to Its Motion for Partial Summary
                  10      Judgment (RAF), and BANA’s Response to Plaintiffs’ Objections to Evidence to Its
                  11      Motion for Partial Summary Judgment (RO). Consistent with the Court’s prior
                  12      sealing Orders finding compelling reasons to seal certain exhibits filed with both
                  13      BANA’s Motion for Partial Summary Judgment (ECF 603), as well as Plaintiffs’
                  14      Opposition to BANA’s Motion for Partial Summary Judgment (MSJ Opp.) (ECF
                  15      639, 654), BANA also seeks to seal references within its Reply, RAF, and RO to the
                  16      contents of those already-filed and sealed Brys and Chan Declaration Exhibits.2
                  17             As previously stated in BANA’s motions to seal submitted in connection with
                  18      class certification briefing and argument (ECF 328, 337, 344, 347, 383, 418, 451)
                  19      and BANA’s motions to seal submitted in connection with summary judgment
                  20      briefing (ECF 577, 579, 581, 583, 585, 587), the public’s right to inspect and copy
                  21
                          1
                  22        The exhibits submitted in support of BANA’s Reply are appended to the Brys
                          Declaration (Brys Decl.) and shall be referred to as “DX” or “Brys Declaration
                  23      Exhibits” in this Motion and the forthcoming Reply and supporting documents. DX
                          1-184 are exhibits to the Declaration of Laura G. Brys (ECF 591) in Support of
                  24      BANA’s Mot. for Partial Summary Judgment (MSJ) (ECF 589). DX 185-192 are
                          exhibits to the Declaration of Laura G. Brys in Support of the Reply. Plaintiffs’
                  25      Exhibits to the Declaration of Connie K. Chan in Opposition to BANA’s MSJ (ECF
                  26      634-1) shall be referred to as “PX” in the forthcoming Reply and supporting
                          documents.
                          2
                  27        BANA incorporates by reference its Motion to File Documents Under Seal (ECF
                          587) in connection with its Motion for Partial Summary Judgment (ECF 589) and
                  28      Plaintiffs’ Motion to File Documents Under Seal (ECF 630, 650) in connection with
GOODWIN PROCTER LLP
                          Plaintiffs’ Opposition to BANA’s Motion for Partial Summary Judgment (ECF 652).
   ATTORNEYS AT LAW                                                1
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY               CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   judicial records is not absolute, and a party faced with the disclosure of confidential
                      2   or proprietary information may seek to file the documents under seal to avoid
                      3   disclosure of business information that might result in competitive harm or be used
                      4   for improper purposes. See Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 598
                      5   (1978) (denying disclosure); Local Civ. R. 79.2(c). A party seeking to seal documents
                      6   filed in connection with a motion for summary judgment, a dispositive motion, must
                      7   show “compelling reasons” to seal documents. Kamakana v. City & Cnty. of
                      8   Honolulu, 447 F.3d 1172, 1179 (9th Cir. 2006); see also Pintos v. Pacific Creditors
                      9   Ass’n, 605 F.3d 665, 678-79 (9th Cir. 2010) (determining “compelling reasons”
                 10       standard applies to motion to seal documents attached to cross-motion for summary
                 11       judgment); EpicentRx, Inc. v. Carter, 2023 WL 4336695, *1 (S.D. Cal. May 16,
                 12       2023) (applying “compelling reasons” standard to request to seal certain exhibits
                 13       associated with motions for summary judgment).
                 14              Courts, including this Court, consistently seal documents where disclosure of
                 15       confidential business information risks competitive harm to the litigant or improper
                 16       use of the information such as to commit fraud. See, e.g., ECF 603; E.W. Bank v.
                 17       Shanker, 2021 WL 3112452, *18-19 (N.D. Cal. July 22, 2021) (finding compelling
                 18       reasons to seal confidential onboarding processes, verification of customer identities,
                 19       and fraud prevention measures); Soria v. U.S. Bank N.A., 2019 WL 8167925, at *4
                 20       (C.D. Cal. Apr. 25, 2019) (finding compelling reasons to seal internal fraud
                 21       investigation procedures because there was a “significant danger that someone could
                 22       improperly use this information to commit fraud and avoid detection.”). Indeed, this
                 23       Court largely granted the Parties’ prior motions to seal, finding good cause or
                 24       compelling reasons to seal documents concerning the same topics that BANA now
                 25       seeks to seal, including BANA’s fraud detection and prevention policies and
                 26       strategies (including the fraud filter), discussions or analyses of its state prepaid
                 27       unemployment program operations, including call center operations, prepaid fraud
                 28       losses, and cardholder complaints and escalations, among other topics. See ECF 266,
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                  2
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY                 CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   293, 365, 381, 390, 391, 397, 421, 466, 467, 548, 598, 599, 600, 601, 602, 603 (the
                      2   Sealing Orders). Those prior rulings are sufficient grounds alone to grant sealing
                      3   here. See Lundstrom v. Young, 2022 WL 15524624, *17 (S.D. Cal. Oct. 27, 2022)
                      4   (Curiel, J.) (considering prior sealing of exhibits when granting motion to seal);
                      5   Workplace Techs. Rsch., Inc. v. Project Mgmt. Inst., Inc., 2021 WL 6091272, *3
                      6   (S.D. Cal. Oct. 20, 2021) (sealing references to document that court already granted
                      7   sealing of).
                      8          Consistent with this Court’s Sealing Orders, there are compelling reasons to
                      9   seal the confidential documents, declaration and testimony at issue here (or
                 10       references thereto), as well as substantive discussions of already sealed exhibits filed
                 11       in connection with BANA’s MSJ and Plaintiffs’ MSJ Opp., because each reflects
                 12       topics that are likely to cause particularized competitive harm to BANA and which
                 13       could potentially enable future fraud, and thus pose a danger to BANA’s business
                 14       and the public. See, e.g., EWB, 2021 WL 3112452, *18-19 (finding compelling
                 15       reasons to seal where public disclosure of EWB’s confidential onboarding processes,
                 16       verification of customer identities and fraud prevention measures would “harm [the
                 17       bank’s] competitive standing”); Soria, 2019 WL 8167925, *4 (finding compelling
                 18       reasons to seal bank’s internal procedures for investigating fraud because there was
                 19       a “significant danger that someone could improperly use this information to commit
                 20       fraud and avoid detection”). Each document was also properly designated as
                 21       “Confidential” or “Highly Confidential – Attorneys’ Eyes Only” under the Protective
                 22       Order entered by this Court. See BAE Systems, 670 F. Supp. 3d at 1069 (finding good
                 23       cause to seal certain exhibits filed in connection with an apex discovery dispute
                 24       because “information in the exhibits fits within ‘confidential information’ in the
                 25       protective order”).
                 26              Specifically, the Confidential documents, declaration and testimony that
                 27       BANA seeks to seal include, but are not limited to, the following categories of
                 28       documents and information, for which this Court has already found compelling
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                  3
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY                  CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   reasons to seal:
                      2              DX 186, 187, and 189 reflect confidential BANA fraud detection and
                      3                prevention strategies and policies, including the Claim Fraud Filter, and
                      4                other current and former fraud strategies that could be misused by
                      5                fraudsters to perpetrate future fraud or could be used by another
                      6                financial institution to BANA’s competitive disadvantage (see
                      7                Amended Sealing Order (ECF 365) at 5-6, 12; Sealing Order (ECF
                      8                603));
                      9              DX 188 reflects confidential BANA claims review policies and
                 10                    strategies and the implementation thereof, including reviewing
                 11                    complaint escalations and issuing provisional credits in compliance with
                 12                    regulations that could also be misused by fraudsters to perpetrate fraud
                 13                    or could be used by another financial institution to BANA’s competitive
                 14                    disadvantage (see Amended Sealing Order (ECF 365) at 5-6, 12; Sealing
                 15                    Order (ECF 603));
                 16                  DX 191 and 192 reflect BANA’s confidential analyses of its state
                 17                    prepaid unemployment program operations, including but not limited to,
                 18                    contractual negotiations, fraud volume, claims and call center
                 19                    operations, and operational risks and losses (see Amended Sealing
                 20                    Order (ECF 365) at 10-13, n.14; Sealing Order (ECF 603));
                 21                  DX 192 reflects confidential BANA fraud and operational losses in
                 22                    connection with the unemployment insurance prepaid programs which
                 23                    could be misused by fraudsters to perpetrate future fraud or could be
                 24                    used by another financial institution to BANA’s competitive
                 25                    disadvantage (see Amended Sealing Order (ECF 365) at 10-13, n.14;
                 26                    Sealing Order (ECF 603));
                 27                  DX 185 reflects an expert witness’s sworn declaration discussing
                 28                    confidential BANA interrogatory responses and data provided therein
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                 4
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY                 CASE NO. 3:21-MD-02992-GPC-MSB
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                      1                reflecting BANA’s use of the Claim Fraud Filter to decision
                      2                unauthorized transaction claims and to freeze or block EDD cardholder
                      3                accounts, and any reconsideration by BANA of those claims and any
                      4                compensation paid as a result which could be misused by fraudsters to
                      5                perpetrate future fraud or could be used by another financial institution
                      6                to BANA’s competitive disadvantage (see Amended Sealing Order
                      7                (ECF 365) at 5-9, 12; Sealing Order (ECF 603));
                      8              DX 190 reflects excerpts of an experts’ deposition testimony, which
                      9                includes discussions of BANA’s confidential documents, many of
                 10                    which contain the confidential information described above, including
                 11                    but not limited to: BANA’s handling of unauthorized transaction claims
                 12                    and reconsiderations. This information could be misused by fraudsters
                 13                    to perpetrate future fraud or could be used by another financial
                 14                    institution to BANA’s competitive disadvantage (see Amended Sealing
                 15                    Order (ECF 365) at 5-9, 12; Sealing Order (ECF 603)); and
                 16                  DX 186, 187, 188, 189, 191, and 192 reflect excerpts of 30(b)(6) and
                 17                    fact witnesses’ deposition testimony, which include discussions of
                 18                    BANA’s confidential documents, many of which contain the
                 19                    confidential information described above, including but not limited to:
                 20                    BANA’s      handling      of   unauthorized     transaction   claims    and
                 21                    reconsiderations; BANA’s contract with EDD and the responsibilities
                 22                    thereunder; BANA’s communications with EDD regarding fraud-
                 23                    related measures; BANA’s fraud strategies, including the use of EMV
                 24                    chip technology and the freezing and blocking of accounts; and BANA’s
                 25                    call center procedures and complaint escalation intake channels. This
                 26                    information could be misused by fraudsters to perpetrate future fraud or
                 27                    could be used by another financial institution to BANA’s competitive
                 28                    disadvantage (see Amended Sealing Order (ECF 365) at 5-9, 12; Sealing
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                   5
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY                  CASE NO. 3:21-MD-02992-GPC-MSB
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                      1                Order (ECF 603)).
                      2          BANA has also provisionally redacted and sealed portions of the Reply, RAF,
                      3   and RO that quote, describe or reflect descriptions of the confidential documents,
                      4   testimony and topics identified above, or those previously submitted or described in
                      5   the Parties’ prior briefing and motions to seal submitted in connection with BANA’s
                      6   MSJ and Plaintiffs’ MSJ Opp. Those confidential topics include: BANA analyses
                      7   pertaining to fraud, including card skimming, and potential fraud prevention and
                      8   detection strategies to combat that fraud; confidential BANA general services
                      9   agreements and statements of work between BANA and its call center vendors;
                 10       confidential BANA communications with EDD regarding BANA’s and/or EDD’s
                 11       fraud strategies, including the use of EMV chip technology and freezing and blocking
                 12       of accounts; confidential BANA documents and testimony pertaining to BANA’s
                 13       Remediation Plan and Addenda with the Office of the Comptroller of the Currency
                 14       (OCC) and the Consumer Financial Protection Bureau (CFPB)—which were
                 15       designated Highly Confidential – Attorneys’ Eyes Only at those regulators’
                 16       requests—which this Court has found compelling reasons to seal; and confidential
                 17       EDD cardholder account or personal information, including personal identifying
                 18       information, the disclosure of which could expose those cardholders to harm or
                 19       identity theft, as well as the types of claims files or information that BANA considers
                 20       in connection with investigating and processing unauthorized transaction and error
                 21       claims, disclosure of which could provide the public with insight into BANA’s
                 22       confidential claims processes or procedures, thereby enabling fraudsters to
                 23       circumvent them and perpetrate future fraud, and the disclosure of which could also
                 24       enable other financial institutions to use that information to BANA’s competitive
                 25       disadvantage, among other topics. This is consistent with the terms of the Stipulated
                 26       Protective Order (ECF 82 § 3), with this Court’s prior Sealing Orders in favor of
                 27       BANA (ECF 266, 293, 365, 381, 390, 391, 397, 421, 466, 467, 548, 598, 599, 600,
                 28       601, 602, 603) and in favor of Plaintiffs (ECF 376, 384, 394, 463, 475, 524, 527, 569,
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                  6
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY                 CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   572, 609, 615, 618 ,630, 650), and with rulings in this Circuit. See, e.g., Darisse v.
                      2   Nest Labs, Inc., 2016 WL 11474174, *2 (N.D. Cal. June 2, 2016) (sealing class
                      3   certification motion and declarations that quote or reference confidential exhibits).
                      4   For the reasons discussed above, there are compelling reasons to seal discussions of
                      5   those topics, testimony and documents discussed in the Parties’ briefing. See supra
                      6   at 3-4.
                      7                                         *      *     *
                      8             For the foregoing reasons and for the reasons set forth in the Court’s Sealing
                      9   Orders in connection with class certification briefing and argument (ECF 365, 381,
                 10       390, 391, 397, 421, 466, 467, 548) and BANA’s Motion for Partial Summary
                 11       Judgment (ECF 603), Plaintiffs’ prior Motions to Seal (ECF 376, 384, 394, 463, 475,
                 12       524, 527, 569, 572, 609, 615, 618 ,630, 650), BANA’s prior Motions to Seal (ECF
                 13       328, 337, 344, 347, 383, 418, 451, 577, 579, 581, 583, 585, 587) and accompanying
                 14       declarations submitted in support thereof (ECF 344-1, 344-2, 344-3, 347-1, 347-2),
                 15       all of which are incorporated herein by reference, BANA respectfully requests that
                 16       the Court grant BANA’s Motion to Seal because compelling reasons support sealing
                 17       thereof.
                 18
                 19        Dated: February 20, 2026            Respectfully submitted,
                 20                                            By: s/ Laura G. Brys
                                                                   LAURA G. BRYS (SBN 242100)
                 21                                                LBrys@goodwinlaw.com
                 22                                                GOODWIN PROCTER LLP
                                                                   601 S. Figueroa St., Suite 4100
                 23                                                Los Angeles, CA 90017
                                                                   Tel.: +1 213 426 2500
                 24                                                Fax: +1 617 346 4444
                 25                                                  JAMES W. MCGARRY (pro hac vice)
                 26                                                  JMcGarry@goodwinlaw.com
                                                                     GOODWIN PROCTER LLP
                 27                                                  100 Northern Avenue
                                                                     Boston, MA 02210
                 28                                                  Tel.: +1 617 570 1000
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                    7
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY                   CASE NO. 3:21-MD-02992-GPC-MSB
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                      1                                           Fax: +1 617 523 1231
                      2                                           SABRINA M. ROSE-SMITH (pro hac vice)
                      3                                           SRoseSmith@goodwinlaw.com
                                                                  MATTHEW L. RIFFEE (pro hac vice)
                      4                                           MRiffee@goodwinlaw.com
                                                                  KEITH LEVENBERG (pro hac vice)
                      5                                           KLevenberg@goodwinlaw.com
                                                                  GOODWIN PROCTER LLP
                      6                                           1900 N Street NW
                      7                                           Washington, DC 20036
                                                                  Tel: +1 202 346 4000
                      8                                           Fax: +1 202 346 4444
                      9                                           Lindsay E. Hoyle (pro hac vice)
                                                                  LHoyle@goodwinlaw.com
                 10                                               VALERIE A. HAGGANS (pro hac vice)
                 11                                               VHaggans@goodwinlaw.com
                                                                  GOODWIN PROCTER LLP
                 12                                               620 Eighth Avenue
                                                                  New York, NY 10018
                 13                                               Tel: +1 212 813-8800
                 14                                               Fax: +1 212 355-3333

                 15                                               YVONNE W. CHAN (pro hac vice)
                                                                  YChan@jonesday.com
                 16                                               JONES DAY
                                                                  100 High Street
                 17                                               Boston, MA 02110
                 18                                               Tel.: +1 617 960 3939
                                                                  Fax: +1 617 449 6999
                 19
                                                                  JANICE P. BROWN (SBN 114433)
                 20                                               jbrown@myersnave.com
                                                                  MATTHEW B. NAZARETH (SBN 278405)
                 21                                               mnazareth@myersnave.com
                 22                                               MEYERS NAVE
                                                                  600 B Street, Suite 1650
                 23                                               San Diego, CA 92101
                 24                                               Attorneys for Defendant
                                                                  BANK OF AMERICA, N.A.
                 25
                 26
                 27
                 28
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                 8
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                      1                             CERTIFICATE OF SERVICE
                      2          I hereby certify that I electronically filed the foregoing with the clerk of the
                      3   court for the United States District Court for the Southern District of California by
                      4   using the CM/ECF system on February 20, 2026. I further certify that all participants
                      5   in the case are registered CM/ECF users and that service will be accomplished by the
                      6   CM/ECF system. I certify under penalty of perjury that the foregoing is true and
                      7   correct.
                      8
                      9    Dated: February 20, 2026                               s/ Laura G. Brys
                  10                                                             LAURA G. BRYS
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GOODWIN PROCTER LLP
   ATTORNEYS AT LAW                                                  9
                          BANA’S MOT. TO SEAL PARTIAL SJ REPLY                 CASE NO. 3:21-MD-02992-GPC-MSB


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