Declaration of Lindsay E. Hoyle — Bofa Ca Unemployment (Dkt. 567.2)

Record facts

U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 567-2 · 2026-04-17 · Docket on CourtListener

Summary

Doc. 567-2 in In re: Bank of America California Unemployment Benefits Litigation, No. 3:21-md-02992-GPC-MSB, in the U.S. District Court for the Southern District of California, is the declaration of Lindsay E. Hoyle, counsel at Goodwin Procter LLP for Defendant Bank of America, N.A., filed October 17, 2025. It supports the bank's motion to exclude the opinions of a plaintiffs' expert, set for hearing April 17, 2026 before Judge Gonzalo P. Curiel. The declaration identifies sixteen exhibits, filed provisionally under seal. Among them are the CFPB Consent Order and the OCC Consent Order, each dated July 14, 2022 (Exhibit 28 and Exhibit 29), and the bank's Remediation Plan (Exhibit 31); the others are expert reports, deposition transcript excerpts and interrogatory responses.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

HOYLE DECL. ISO BANA’S MOT. TO EXCLUDE REGAN 
 
CASE NO. 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 LINDSAY E. 
HOYLE IN SUPPORT OF 
DEFENDANT BANK OF 
AMERICA, N.A’S MOTION TO 
EXCLUDE PURPORTED 
EXPERT OPINIONS OF GREG J. 
REGAN 
 
Date: 
April 17, 2026 
Time: 
1:30 p.m. 
Ctrm: 
12A – 12th FLoor  
Judge: 
Hon. Gonzalo P. Curiel 
EXHIBITS FILED PROVISIONALLY UNDER 
SEAL PURSUANT TO STIPULATED 
PROTECTIVE ORDER 
Case 3:21-md-02992-GPC-MSB     Document 567-2     Filed 10/17/25     PageID.33931 
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HOYLE DECL. ISO BANA’S MOT. TO EXCLUDE REGAN 
 
ASE NO. 21-MD-02992-GPC-MSB
 
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GOODWIN PROCTER LLP 
ATTORNEYS AT LAW 
I, Lindsay E. Hoyle, state and declare as follows: 
1. 
I am Counsel at Goodwin Procter LLP, and counsel of record for 
Defendant Bank of America, N.A. (BANA) in the above-captioned lawsuit. 
2. 
I have personal knowledge of the facts set forth in this declaration, and 
if called upon to do so, I could and would competently testify thereto. 
3. 
I make this declaration in support of BANA’s Motion to Exclude the 
Purported Expert Opinions of Greg J. Regan. 
4. 
Attached hereto as Exhibit 28 is a true and correct copy of the CFPB 
Consent Order, dated July 14, 2022. 
5. 
Attached hereto as Exhibit 29 is a true and correct copy of the OCC 
Consent Order, dated July 14, 2022. 
6. 
Attached hereto as Exhibit 30 is a true and correct copy of excerpts from 
the official transcript of Plaintiffs’ deposition of BANA’s 30(b)(6) designee, Jennifer 
Lennon, taken on February 23, 2024. 
7. 
Attached hereto as Exhibit 31 is a true and correct copy of BANA’s 
Remediation Plan, a document produced by BANA in this action Bates stamped 
BANA_EDD_MDL-00102554. 
8. 
Attached hereto as Exhibit 34 is a true and correct copy of the Expert 
Rebuttal Report of Justin McCrary, and appendices thereto, dated April 4, 2025. 
9. 
Attached hereto as Exhibit 35 is a true and correct copy of the Expert 
Report of David I. Levine, and appendices thereto, dated March 4, 2025. 
10. 
Attached hereto as Exhibit 37 is a true and correct copy of excerpts from 
Plaintiff Stephanie Moore’s Supplemental Objections and Responses to Bank of 
America, N.A.’s First Set of Interrogatories, dated January 29, 2024. 
11. 
Attached hereto as Exhibit 39 is a true and correct copy of excerpts from 
the official transcript of BANA’s deposition of Expert Greg Regan, taken on May 
19, 2025. 
Case 3:21-md-02992-GPC-MSB     Document 567-2     Filed 10/17/25     PageID.33932 
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HOYLE DEC. ISO BANA’S MOT. TO EXCLUDE REGAN 
 
CASE NO. 21-MD-02992-GPC-MSB 
 
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GOODWIN PROCTER LLP 
ATTORNEYS AT LAW 
12. 
Attached hereto as Exhibit 40 is a true and correct copy of the Expert 
Report of Victor Stango, and appendices thereto, dated April 4, 2025. 
13. 
Attached hereto as Exhibit 41 is a true and correct copy of the Expert 
Report of Greg Regan, and appendices thereto, dated March 4, 2025.  
14. 
Attached hereto as Exhibit 42 is a true and correct copy of excerpts from 
BANA’s Second Set of Responses and Objections to Plaintiff Yick’s Seventh Set of 
Interrogatories, dated April 23, 2024. 
15. 
Attached hereto as Exhibit 43 is a true and correct copy of excerpts from 
Plaintiff Roland Oosthuizen’s Supplemental Objections and Responses to Bank of 
America, N.A.’s First Set of Interrogatories, dated January 29, 2024. 
16. 
Attached hereto as Exhibit 44 is a true and correct copy of excerpts from 
Plaintiff J. Michael Willrich’s Supplemental Objections and Responses to Bank of 
America, N.A.’s First Set of Interrogatories, dated January 29, 2024. 
17. 
Attached hereto as Exhibit 45 is a true and correct copy of excerpts from 
Plaintiff Alex Yuan’s Supplemental Objections and Responses to Bank of America, 
N.A.’s First Set of Interrogatories, and exhibits thereto, dated January 29, 2024. 
18. 
Attached hereto as Exhibit 46 is a true and correct copy of excerpts from 
Plaintiff Vanessa Rivera’s Objections and Supplemental Responses to Bank of 
America, N.A.’s First Set of Interrogatories, dated January 29, 2024. 
19. 
Attached hereto as Exhibit 47 is a true and correct copy of excerpts from 
the official transcript of Plaintiff’s deposition of BANA’s Rule 30(b)(6) designee, 
Robert A. Chestnut, taken on February 8, 2024. 
 
I declare under penalty of perjury that the foregoing is true and correct. 
Executed on October 17, 2025, in Old Greenwich, CT. 
/s/ Lindsay E. Hoyl e 
 
 
LINDSAY E. HOYLE 
 
 
Case 3:21-md-02992-GPC-MSB     Document 567-2     Filed 10/17/25     PageID.33933 
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