MOTION to File Documents Under Seal — Bofa Ca Unemployment (Dkt. 612)

Record facts

U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 612 · 2026-04-17 · Docket on CourtListener

Summary

A motion to file documents under seal, filed January 8, 2026 as Document 612 in In re Bank of America California Unemployment Benefits Litigation, No. 3:21-md-02992-GPC-MSB, in the United States District Court for the Southern District of California. Co-lead counsel for the plaintiffs move, under Local Rule 79.2, Section 12.5 of the Stipulated Protective Order (ECF 82) and the court's Civil Pretrial & Trial Procedures, to seal material in their opposition to the bank's motion to exclude certain opinions of a plaintiffs' expert. It lists six categories: portions of the opposition that quote or refer to material the bank designated Highly Confidential or Confidential, portions of the expert's report, rebuttal report and deposition, and Exhibit 8 and Exhibit 15 to the bank's deposition of him, designated Confidential in their entirety. The four-page filing carries a signature attestation.

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Full text

Motion to File Documents Under Seal; Case No. 3:21-md-02992-GPC-MSB
 
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JOSEPH W. COTCHETT (SBN 36324) 
jcotchett@cpmlegal.com 
BRIAN DANITZ (SBN 247403) 
bdanitz@cpmlegal.com 
KARIN B. SWOPE (Pro Hac Vice) 
kswope@cpmlegal.com 
VASTI S. MONTIEL (SBN 346409) 
vmontiel@cpmlegal.com 
CAROLINE A. YUEN (SBN 354388) 
cyuen@cpmlegal.com 
COTCHETT, PITRE & McCARTHY, LLP 
840 Malcolm Road, Suite 200 
Burlingame, CA 94010 
Telephone: (650) 697-6000 
Fax: (650) 697-0577 
MICHAEL RUBIN (SBN 80618) 
mrubin@altber.com 
STACEY M. LEYTON (SBN 203827) 
sleyton@altber.com 
CONNIE K. CHAN (SBN 284230) 
cchan@altber.com 
JAMES BALTZER (SBN 332232) 
jbaltzer@altber.com 
KATHERINE BASS (SBN 344748) 
kbass@altber.com 
ALTSHULER BERZON LLP 
177 Post Street, Suite 300 
San Francisco, CA 94108 
Telephone: (415) 421-7151 
Fax: (415) 362-8064 
Co-Lead Counsel for Plaintiffs and the Class  
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA 
IN RE BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
Case No. 3:21-md-02992-GPC-MSB 
 
MOTION TO FILE DOCUMENTS 
UNDER SEAL RE:  PLAINTIFFS’ 
OPPOSITION TO DEFENDANT’S 
MOTION TO EXCLUDE CERTAIN 
EXPERT OPINIONS OF JAY 
MINNUCCI 
 
This Document Relates to All Actions 
Date: 
 
April 17, 2026 
Time:  
1:30 p.m. 
Judge:  
Hon. Gonzalo P. Curiel 
Ctrm:  
2D (2nd Floor) 
Case 3:21-md-02992-GPC-MSB     Document 612     Filed 01/08/26     PageID.43387     Page
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Motion to File Documents Under Seal; Case No. 3:21-md-02992-GPC-MSB 
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Pursuant to Local Rule 79.2 and Section 12.5 of the Stipulated Protective Order 
(ECF 82) in this case and the Court’s Civil Pretrial & Trial Procedures, Plaintiffs move to 
file under seal the following: 
1. Portions of Plaintiffs’ Opposition to Defendant’s Motion to Exclude Certain 
Expert Opinions of Jay Minnucci, which quote or otherwise refer to portions of 
the Expert Report of Jay Minnucci which Defendant Bank of America, N.A. (the 
“Bank”) has designated Highly Confidential, excerpts of the deposition of Jay 
Minnucci which was designated Confidential by the Bank, Exhibit 8 to the 
Bank’s deposition of Jay Minnucci which the Bank has designated Confidential 
in its entirety, and Exhibit 15 to the Bank’s deposition of Jay Minnucci which the 
Bank has designated Confidential in its entirety. 
2. Portions of the Expert Report of Jay Minnucci which the Bank has designated 
Highly Confidential. 
3. Portions of the Expert Rebuttal Report of Jay Minnucci which refer to materials 
which the Bank has designated Highly Confidential. 
4. Portions of the deposition of Jay Minnucci which the Bank has designated 
Confidential. 
5. Exhibit 8 to the Bank’s deposition of Plaintiffs’ expert Jay Minnucci which the 
Bank has designated Confidential in its entirety. 
6. Exhibit 15 to the Bank’s deposition of Plaintiffs’ expert Jay Minnucci which the 
Bank has designated Confidential in its entirety. 
Respectfully submitted, 
Dated:  January 8, 2026  
COTCHETT, PITRE & McCARTHY, LLP 
 
By:  /s/ Brian Danitz 
 
 
 
JOSEPH W. COTCHETT  
BRIAN DANITZ  
KARIN B. SWOPE  
BLAIR V. KITTLE 
VASTI S. MONTIEL 
CAROLINE A. YUEN 
REGINA WANG 
 
Case 3:21-md-02992-GPC-MSB     Document 612     Filed 01/08/26     PageID.43388     Page
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Motion to File Documents Under Seal; Case No. 3:21-md-02992-GPC-MSB 
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Dated:  January 8, 2026  
ALTSHULER BERZON LLP 
 
By:  /s/ Michael Rubin  
 
 
 
 
 
 
 
  
 
MICHAEL RUBIN  
STACEY M. LEYTON  
CONNIE K. CHAN 
 
 
 
 
 
 
JAMES BALTZER 
 
 
 
 
 
 
KATHERINE G. BASS 
 
Co-Lead Counsel for Plaintiffs and  
the Class   
 
 
Case 3:21-md-02992-GPC-MSB     Document 612     Filed 01/08/26     PageID.43389     Page
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Motion to File Documents Under Seal; Case No. 3:21-md-02992-GPC-MSB 
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SIGNATURE ATTESTATION 
Pursuant to section 2(f)(4) of the Electronic Case Filing Administrative Policies and 
Procedures Manual, I, Brian Danitz, attest that the other signatories listed, and on whose 
behalf this filing is submitted, concur in the filing content and have authorized this filing. 
 
Dated: January 8, 2026  
 
 
/s/ Brian Danitz 
 
 
BRIAN DANITZ 
Case 3:21-md-02992-GPC-MSB     Document 612     Filed 01/08/26     PageID.43390     Page
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