MOTION to File Documents Under Seal — Bofa Ca Unemployment (Dkt. 618)

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Plaintiffs' Motion to File Documents Under Seal Re: Plaintiffs' Opposition to Defendant's Motion to Exclude Certain Expert Opinions of Greg J. Regan, filed 01/08/26 as Document 618 in In re Bank of America California Unemployment Benefits Litigation, Case No. 3:21-md-02992-GPC-MSB in the Southern District of California. Under Local Rule 79.2 and the Stipulated Protective Order (ECF 82), plaintiffs ask to seal portions of their opposition that quote the Court's previously sealed Order Granting Class Certification, and portions of Regan's March 4, 2025 and August 29, 2024 reports. They also ask to seal the April 4, 2025 expert reports of Victor Stango and Justin McCrary, which Bank of America designated highly confidential in their entirety.

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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  
GREG J. REGAN 
 
Judge: Hon. Gonzalo P. Curiel 
Ctrm: 2D (2nd Floor)
 
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 618     Filed 01/08/26     PageID.43892     Page
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Motion to File Documents Under Seal; Case No. 3:21-md-02992-GPC-MSB 
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MOTION TO FILE DOCUMENTS UNDER SEAL 
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 Daubert Motion to Exclude 
Certain Expert Opinions of Greg J. Regan, which quote portions of the Court’s 
Order Granting Class Certification that this Court previously ordered sealed. See 
ECF 494, 498. 
2. Portions of the March 4, 2025 Expert Report of Greg J. Regan, attached as 
Exhibit A to the Declaration of James Baltzer in Support of Plaintiffs’ Opposition 
to Defendant’s Daubert Motion to Exclude Certain Expert Opinions of Greg J. 
Regan, which have been designated confidential pursuant to the Stipulated 
Protective Order. 
3. Portions of the August 29, 2024 Expert Report of Greg J. Regan, attached as 
Exhibit B to the Declaration of James Baltzer in Support of Plaintiffs’ Opposition 
to Defendant’s Daubert Motion to Exclude Certain Expert Opinions of Greg J. 
Regan, portions of which have been designated confidential pursuant to the 
Stipulated Protective Order.  
4. The April 4, 2025 Expert Report of Victor Stango, attached as Exhibit C to the 
Declaration of James Baltzer in Support of Plaintiffs’ Opposition to Defendant’s 
Daubert Motion to Exclude Certain Expert Opinions of Greg J. Regan, which 
Defendant Bank of America, N.A. has designated highly confidential in its 
entirety.  
5. The April 4, 2025 Expert Report of Justin McCrary, attached as Exhibit D to the 
Declaration of James Baltzer in Support of Plaintiffs’ Opposition to Defendant’s 
Daubert Motion to Exclude Certain Expert Opinions of Greg J. Regan, which 
Defendant Bank of America, N.A. has designated highly confidential in its 
entirety.  
Case 3:21-md-02992-GPC-MSB     Document 618     Filed 01/08/26     PageID.43893     Page
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Motion to File Documents Under Seal; Case No. 3:21-md-02992-GPC-MSB 
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6. Portions of Plaintiffs’ Opposition to Defendant’s Daubert Motion to Exclude 
Certain Expert Opinions of Greg J. Regan, which quote or discuss portions of the 
March 4, 2025 and August 29, 2024 Expert Reports of Greg J. Regan, portions 
of which have been designated confidential pursuant to the Stipulated Protective 
Order. 
7. Portions of Plaintiffs’ Opposition to Defendant’s Daubert Motion to Exclude 
Certain Expert Opinions of Greg J. Regan, which quote or discuss portions of the 
Expert Report of Victor Stango, which Defendant Bank of America, N.A. has 
designated highly confidential in its entirety.  
8. Portions of Plaintiffs’ Opposition to Defendant’s Daubert Motion to Exclude 
Certain Expert Opinions of Greg J. Regan, which quote or discuss portions of the 
Expert Report of Justin McCrary, which Defendant Bank of America, N.A. has 
designated highly confidential in its entirety.  
Respectfully submitted, 
Dated:  January 8, 2025  
 
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 
 
Dated:  January 8, 2025  
 
ALTSHULER BERZON LLP 
 
By:  /s/ Connie K. Chan 
 
 
 
 
 
  
 
MICHAEL RUBIN  
STACEY M. LEYTON 
CONNIE K. CHAN 
 
 
 
 
 
 
JAMES BALTZER 
KATHERINE BASS 
 
Co-Lead Counsel for Plaintiffs and the Class 
Case 3:21-md-02992-GPC-MSB     Document 618     Filed 01/08/26     PageID.43894     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 618     Filed 01/08/26     PageID.43895     Page
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