Exhibit DX 185 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 693-5, 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. 693-5 · 2026-02-20 · Docket on CourtListener

Full text

DX 185
REDACTED VERSION 
OF
DOCUMENT 
SOUGHT TO
BE SEALED 
PURSUANT TO 
STIPULATED 
PROTECTIVE ORDER
Case 3:21-md-02992-GPC-MSB     Document 693-5     Filed 02/20/26     PageID.59514 
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STANGO DECL. ISO SJ REPLY 
CASE NO. 3:21-MD-02992-GPC-MSB 
 
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GOODWIN PROCTER LLP 
ATTORNEYS AT LAW 
JAMES W. MCGARRY (pro hac vice) 
JMcGarry@goodwinlaw.com 
GOODWIN PROCTER LLP 
100 Northern Avenue 
Boston, MA 02210 
Tel.: +1 617 570 1000  
Fax: +1 617 523 1231 
 
SABRINA M. ROSE-SMITH (pro hac vice) 
SRoseSmith@goodwinlaw.com 
MATTHEW L. RIFFEE (pro hac vice) 
MRiffee@goodwinlaw.com 
GOODWIN PROCTER LLP 
1900 N Street, NW 
Washington, DC 20036 
Tel.: +1 202 346 4000  
Fax: +1 202 346 4444 
 
Attorneys for Defendant  
BANK OF AMERICA, N.A. 
 
 
 
 
UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF CALIFORNIA  
SAN DIEGO DIVISION 
IN RE: BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
Case No. 21-MD-02992-GPC-MSB 
DECLARATION OF VICTOR 
STANGO IN SUPPORT OF 
DEFENDANT BANK OF AMERICA, 
N.A’S REPLY IN SUPPORT OF ITS 
MOTION FOR PARTIAL SUMMARY 
JUDGMENT (ECF 589) 
Ctrm: 
12A – 12th Floor 
Judge: 
Hon. Gonzalo P. Curiel 
FILED PROVISIONALLY UNDER SEAL 
PURSUANT TO STIPULATED PROTECTIVE 
ORDER 
 
 
Case 3:21-md-02992-GPC-MSB     Document 693-5     Filed 02/20/26     PageID.59515 
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STANGO DECL. ISO SJ REPLY 
CASE NO. 3:21-MD-02992-GPC-MSB 
 
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GOODWIN PROCTER LLP 
ATTORNEYS AT LAW 
I, Victor Stango, state and declare as follows: 
1. 
I am over 18 years of age and am competent to testify in this matter. 
2. 
I have been retained by Defendant Bank of America, N.A. (BANA) to 
serve as an expert in this case. 
3. 
I make this declaration in support of BANA’s Reply in Support of its 
Motion for Partial Summary Judgment. 
4. 
I have been instructed by counsel to perform calculations using 
Plaintiffs’ expert Greg Regan’s Schedule 1, which consists of Mr. Regan’s summary 
of data previously provided by BANA in response, in part, to Interrogatories Nos. 2, 
4, 5, 6, 21, and 46 (BANA’s Interrogatory Data) as it pertains to (a) 
 
, (b) 
, and (c) 
.1 
5. 
In performing my calculations, I also reviewed the BANA Interrogatory 
Data that Mr. Regan summarized, and confirmed that data in Mr. Regan’s Schedule 
1 pertaining to (a) 
, and (b) 
 accurately reflect 
BANA’s Interrogatory Data. 
6. 
My calculations demonstrate that Mr. Regan’s Schedule 1 and BANA’s 
Interrogatory Data reflect that 
 for the Claim Denial 
and Credit Rescission Classes’ unauthorized transaction claims (1) prior to June 9, 
2021, which I understand was the effective date of the Preliminary Injunction issued 
in Yick v. Bank of America, N.A., Case No. 3:21-cv-00376-VC (N.D. Cal.) (ECF 103), 
and (2) prior to issuance and filing of the Office of the Comptroller of the Currency 
(OCC) and Consumer Financial Protection Bureau (CFPB) Consent Orders on July 
14, 2022.2  
a. Based on my review and analysis, prior to and including June 9, 2021, 
 
1 An excerpted copy of Mr. Regan’s Schedule 1 can be found at DX 14.AB.1, filed 
in connection with ECF 589. A full copy of Mr. Regan’s Schedule 1 can be found at 
HX 41.A, filed in connection with ECF 659. Excerpted copies of the BANA 
Interrogatory Response and Data filed in connection with ECF 589 can be found at 
DX 27, DX 27.A, DX 27.B, DX 28.A.1, and DX 31.B.1. 
2 DX 43.A (BANA_EDD_MDL_00102554) at 554–555. 
Case 3:21-md-02992-GPC-MSB     Document 693-5     Filed 02/20/26     PageID.59516 
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BANA paid 
in principal amounts relating to 
claims or rescinded credits included in Mr. Regan's Schedule 1, 
comprising-
claims -
) paid to -
members -
) of 
the Claim Denial and Credit Recission Classes ( of which -
members -
) were fully paid back). 
b. Based on my review and analysis, prior to and including July 14, 2022, 
BANA paid 
-
) in principal amounts relating to 
claims or rescinded credits included in Mr. Regan's Schedule 1, 
comprising-
claims -
) paid to -
members -
) of 
the Claim Denial and Credit Recission Classes ( of which -
members -
) were fully paid back). 
13 
I declare under penalty of perjury that the foregoing is true and correct. 
14 
Executed on February 19, 2026 in Vientiane, Laos. 
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GooDWIN PROCTER LLP 
ATT'ORN'EYSATlJ.W 
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STANGO DECL. ISO SJ REPLY 
CASE No. 3:21-MD-02992-GPC-MSB 
Case 3:21-md-02992-GPC-MSB     Document 693-5     Filed 02/20/26     PageID.59517 
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