Court filing
Declaration re 633 Response in Opposition to Motion — In re Bank of America California Unemployment Benefits Litigation (Dkt. 634, S.D. Cal. No. 3:21-md-02992)
Filed April 17, 2026 in In re Bank of America California Unemployment Benefits Litigation; one of 1415 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of California |
|---|---|
| Filed | 2026-04-17 |
U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 634 · 2026-04-17 · Docket on CourtListener
Full text
DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
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
DECLARATION OF CONNIE K.
CHAN IN OPPOSITION TO MOTION
FOR PARTIAL SUMMARY
JUDGMENT
[ORAL ARGUMENT REQUESTED]
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 634 Filed 01/09/26 PageID.51566 Page
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
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DECLARATION OF CONNIE K. CHAN
I, Connie K. Chan, hereby declare as follows:
1.
I am a partner at the law firm of Altshuler Berzon LLP, co-lead counsel for
Plaintiffs and the certified classes in this action. I submit this declaration in Opposition to
Defendant Bank of America, N.A.’s (the “Bank”) Motion for Partial Summary Judgment.
I have personal knowledge of the facts set forth in this declaration and if called as a
witness in this action, I could and would testify competently to these facts.
2.
Attached hereto as PX 1 is a true and correct copy of the Expert Report of J.
Daniel Kreis dated March 4, 2025, and appendices thereto.
3.
Attached hereto as PX 2 is a true and correct copy of the Expert Report of
Jane Cloninger dated March 4, 2025, and appendices thereto.
4.
Attached hereto as PX 3 is a true and correct copy of the Expert Report of
Jay Minnucci dated March 4, 2025, and appendices thereto.
5.
Attached hereto as PX 4 is a true and correct copy of the Expert Report of
William J. Abernathy, Jr. dated March 3, 2025, and appendices thereto.
6.
Attached hereto as PX 5 is a true and correct copy of the Expert Report of
Greg J. Regan, CPA/CFF, CFE, dated March 4, 2025, and appendices thereto.
7.
Attached hereto as PX 6 is a true and correct copy of the Expert Report of
David I. Levine dated March 4, 2025, and appendices thereto.
8.
Attached hereto as PX 7 is a true and correct copy of the Expert Report of
Chloe N. East dated March 4, 2025, and appendices thereto.
9.
Attached hereto as PX 8 is a true and correct copy of the Expert Rebuttal
Report of J. Daniel Kreis dated April 4, 2025, and appendices thereto.
10.
Attached hereto as PX 9 is a true and correct copy of the Expert Rebuttal
Report of William J. Abernathy Jr. dated April 3, 2025, and appendices thereto.
11.
Attached hereto as PX 10 is a true and correct copy of the Expert Rebuttal
Report of Natalie Loebner dated April 4, 2025, and appendices thereto.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
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12.
Attached hereto as PX 11 is a true and correct copy of the Expert Rebuttal
Report of Jane Cloninger dated April 4, 2025, and appendices thereto.
13.
Attached hereto as PX 12 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Defendant Bank of America, N.A.’s (“Defendant,”
“BANA,” or the “Bank”) Rule 30(b)(6) designee, Shane Daniels, taken on February 6,
2024 (“Daniels 30(b)(6) Deposition”).
14.
Attached hereto as PX 13 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s Rule 30(b)(6) designee, Robert Chestnut,
taken on February 8, 2024 (“Chestnut 30(b)(6) Deposition”).
15.
Attached hereto as PX 14 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s Rule 30(b)(6) designee, William (“Matt”)
Martin, taken on February 14, 2024 (“Martin 30(b)(6) Deposition”).
16.
Attached hereto as PX 15 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s Rule 30(b)(6) designee, Michael Letson,
taken on February 16, 2024 (“Letson 30(b)(6) Deposition”).
17.
Attached hereto as PX 16 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s Rule 30(b)(6) designee, William Golden,
taken on February 22, 2024 (“Golden 30(b)(6) Deposition”).
18.
Attached hereto as PX 17 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s Rule 30(b)(6) designee, Jennifer Lennon,
taken on February 23, 2024 (“Lennon 30(b)(6) Deposition”).
19.
Attached hereto as PX 18 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Renee Johnson, taken on May 7, 2024 (“Johnson
Deposition”).
20.
Attached hereto as PX 19 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Ryan Schwartz, taken on December 4, 2024
(“Schwartz Deposition”).
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
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21.
Attached hereto as PX 20 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Brad Garfield, taken on December 10, 2024
(“Garfield Deposition”).
22.
Attached hereto as PX 21 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Faiz Ahmad, taken on January 29, 2025 (“Ahmad
Deposition”).
23.
Attached hereto as PX 22 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of William J. Fox, taken on February 13, 2025 (“Fox
Deposition”).
24.
Attached hereto as PX 23 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Anne Holt, taken on January 8, 2025 (“Holt
Deposition”).
25.
Attached hereto as PX 24 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Jennifer Ehresman, taken on February 19, 2025
(“Ehresman Deposition”).
26.
Attached hereto as PX 25 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Melissa Ramirez, taken on February 11, 2025
(“Ramirez Deposition”).
27.
Attached hereto as PX 26 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Paul Simpson, taken on February 21, 2025
(“Simpson Deposition”).
28.
Attached hereto as PX 27 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Thomas Montag, taken on September 24, 2025
(“Montag Deposition”).
29.
Attached hereto as PX 28 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of Brian Moynihan, taken on October 2, 2025
(“Moynihan Deposition”).
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JUDGMENT
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30.
Attached hereto as PX 29 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of California Employment Development Department’s
designee, Shameel Singh, taken on May 8, 2025 (“EDD Deposition”).
31.
Attached hereto as PX 30 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s expert, Teresa Pesce, taken on May 8,
2025 (“Pesce Deposition”).
32.
Attached hereto as PX 31 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s expert, Pamela Joseph, taken on May 12,
2025 (“Joseph Deposition”).
33.
Attached hereto as PX 32 is a true and correct copy of excerpts from the
transcript of Plaintiffs’ deposition of the Bank’s expert, Carl Pry, taken on May 16, 2025
(“Pry Deposition”).
34.
Attached hereto as PX 33 is a true and correct copy of excerpts of a
document titled, “Response to State of California Electronic Benefits Payments RFP Vol
I & II,” dated July 10, 2015, which was marked Exhibit 26 to the Chestnut 30(b)(6)
Deposition.
35.
Attached hereto as PX 34 is a true and correct copy of a document the Bank
produced Bates-stamped BANA_EDD_MDL-00518186-91, a copy of which was marked
Exhibit 27 to the Chestnut 30(b)(6) Deposition, and the content of which was
subsequently reproduced by the Bank on the public docket, see DX 39 at -2286-2291..
36.
Attached hereto as PX 35 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00187047-60.
37.
Attached hereto as PX 36 is a true and correct copy of the Declaration of
Meiriely Amaral in Support of Plaintiffs’ Motion for a Preliminary Injunction, filed at
ECF 64-1 in Yick v. Bank of America, Case No. 3:21-cv-00376-VC (N.D. Cal.) (“Yick”)
(“Amaral Declaration”), and Exhibit 3 thereto, docketed at Yick, ECF 64-4.
38.
Attached hereto as PX 37 is a true and correct copy of Exhibit 4 to the
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
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Amaral Declaration, docketed at Yick, ECF 64-5.
39.
Attached hereto as PX 38 is a true and correct copy of Exhibit 5 to the
Amaral Declaration, docketed at Yick, ECF 64-6.
40.
Attached hereto as PX 39 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00153666-75, which was
marked Exhibit 32 to the Chestnut 30(b)(6) Deposition.
41.
Attached hereto as PX 40 is a true and correct copy of excerpts from the
transcript of Defendant’s deposition of Vanessa Rivera, taken on February 29, 2024
(“Rivera Deposition”).
42.
Attached hereto as PX 41 is a true and correct copy of excerpts from the
transcript of Defendant’s deposition of Lindsey McClure, taken on March 12, 2024
(“McClure Deposition”).
43.
Attached hereto as PX 42 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00071231-35, which was
marked Exhibit 209 to the Garfield Deposition.
44.
Attached hereto as PX 43 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00452826-27, which was
marked Exhibit 69 to the Letson 30(b)(6) Deposition.
45.
Attached hereto as PX 44 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00421427-28, which was
marked Exhibit 357 to the Fox Deposition.
46.
Attached hereto as PX 45 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-0071588-91, which was
marked Exhibit 29 to the Chestnut 30(b)(6) Deposition.
47.
Attached hereto as PX 46 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00705532–35, which was
marked Exhibit 30 to the Chestnut 30(b)(6) Deposition.
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JUDGMENT
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48.
Attached hereto as PX 47 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00139423-25, which was
marked Exhibit 202 to the Schwartz Deposition.
49.
Attached hereto as PX 48 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00077223-25, a copy of
which was marked Exhibit 25 to the Daniels 30(b)(6) Deposition.
50.
Attached hereto as PX 49 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00417555-58, which was
marked Exhibit 378 to the Ehresman Deposition.
51.
Attached hereto as PX 50 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00153421-22, which was
marked Exhibit 205 to the Garfield Deposition.
52.
Attached hereto as PX 51 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
BANA_EDD_MDL-00718724, which was transcribed as described in the Declaration of
Kelly Koehnen Aristides in Support of Plaintiffs’ Opposition to Motion for Partial
Summary Judgment, attached hereto as PX 298 (“Aristides Declaration”).
53.
Attached hereto as PX 52 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
BANA_EDD_MDL-00887519, which was transcribed as described in the Aristides
Declaration.
54.
Attached hereto as PX 53 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
BANA_EDD_MDL-00888143, which was transcribed as described in the Aristides
Declaration.
55.
Attached hereto as PX 54 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
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BANA_EDD_MDL-00887900, which was transcribed as described in the Aristides
Declaration.
56.
Attached hereto as PX 55 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
BANA_EDD_MDL-00887844, which was transcribed as described in the Aristides
Declaration.
57.
Attached hereto as PX 56 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00536398-406, and
subsequently reproduced by the Bank on the public docket, see ECF 328 at 3 n.3.
58.
Attached hereto as PX 57 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00167414-15, which was
marked Exhibit 210 to the Garfield Deposition.
59.
Attached hereto as PX 58 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00001312-30, which was
marked Exhibit 6 to the Daniels 30(b)(6) Deposition.
60.
Attached hereto as PX 59 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00004535-80, which was
marked Exhibit 5 to the Daniels 30(b)(6) Deposition.
61.
Attached hereto as PX 60 is a true and correct copy of documents produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00559693-94,
BANA_EDD_MDL-559893-926, and BANA_EDD_MDL-559979-80.
62.
Attached hereto as PX 61 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00006482-535, which was
marked Exhibit 181 to the Johnson Deposition.
63.
Attached hereto as PX 62 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_ EDD_MDL-00003887-911, which was
marked Exhibit 182 to the Johnson Deposition.
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JUDGMENT
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64.
Attached hereto as PX 63 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00290330-34, which was
marked Exhibit 82 to the Letson 30(b)(6) Deposition.
65.
Attached hereto as PX 64 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00169953-57, which was
marked Exhibit 278 to the Holt Deposition.
66.
Attached hereto as PX 65 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00630749-53, which was
marked Exhibit 186 to the Schwartz Deposition.
67.
Attached hereto as PX 66 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00169912-15, which was
marked Exhibit 84 to the Letson 30(b)(6) Deposition.
68.
Attached hereto as PX 67 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00416779-80, which was
marked Exhibit 366 to the Ehresman Deposition.
69.
Attached hereto as PX 68 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00701418-22, which was
marked Exhibit 410 to the Montag Deposition.
70.
Attached hereto as PX 69 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00225375-93, which was
marked Exhibit 79 to the Letson 30(b)(6) Deposition.
71.
Attached hereto as PX 70 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00426407-11, which was
marked Exhibit 224 to the Garfield Deposition.
72.
Attached hereto as PX 71 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00181661-63, which was
marked Exhibit 368 to the Ehresman Deposition.
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73.
Attached hereto as PX 72 is a true and correct copy of excerpts of
Defendant’s Responses and Objections to Plaintiffs’ Sixth Set of Interrogatories.
74.
Attached hereto as PX 73 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00706201-03, which was
marked Exhibit 216 to the Garfield Deposition.
75.
Attached hereto as PX 74 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00371658-59.
76.
Attached hereto as PX 75 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00695592-97, which was
marked Exhibit 415 to the Moynihan Deposition.
77.
Attached hereto as PX 76 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00630836, which was
marked Exhibit 190 to the Schwartz Deposition and Exhibit 416 to the Moynihan
Deposition.
78.
Attached hereto as PX 77 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00371977, which was
marked Exhibit 83 to the Letson 30(b)(6) Deposition.
79.
Attached hereto as PX 78 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00057704-12, which was
marked Exhibit 149 to the Johnson Deposition.
80.
Attached hereto as PX 79 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00630837-38, which was
marked Exhibit 192 to the Schwartz Deposition and Exhibit 277 to the Holt Deposition.
81.
Attached hereto as PX 80 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-006125014-15, which was
marked Exhibit 191 to the Schwartz Deposition.
82.
Attached hereto as PX 81 is a true and correct copy of a document produced
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by the Bank in this action Bates-stamped BANA_EDD_MDL-0087749-51, which was
marked Exhibit 193 to the Schwartz Deposition and Exhibit 74 to the Letson Deposition.
83.
Attached hereto as PX 82 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00372012-13, which was
marked Exhibit 417 to the Moynihan Deposition.
84.
Attached hereto as PX 83 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00118367, which was
marked Exhibit 409 to the Moynihan Deposition.
85.
Attached hereto as PX 84 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-0069488-90, which was
marked Exhibit 411 to the Montag Deposition.
86.
Attached hereto as PX 85 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00125058-59, which was
marked Exhibit 283 to the Holt Deposition.
87.
Attached hereto as PX 86 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00170045-47, which was
marked Exhibit 284 to the Holt Deposition.
88.
Attached hereto as PX 87 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00087766-69, which was
marked Exhibit 285 to the Holt Deposition.
89.
Attached hereto as PX 88 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00087779-80, which was
marked Exhibit 289 to the Holt Deposition.
90.
Attached hereto as PX 89 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00125177-79, a copy of
which was marked Exhibit 68 to the Letson 30(b)(6) Deposition.
91.
Attached hereto as PX 90 is a true and correct copy of a document produced
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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by the Bank in this action Bates-stamped BANA_EDD_MDL-00450516-18, which was
marked Exhibit 85 to the Letson 30(b)(6) Deposition.
92.
Attached hereto as PX 91 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00087760-65, which was
marked Exhibit 75 to the Letson 30(b)(6) Deposition.
93.
Attached hereto as PX 92 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00881823-28, which was
marked Exhibit 203 to the Schwartz Deposition.
94.
Attached hereto as PX 93 is a true and correct copy of excerpts of
Defendant’s Responses and Objections to Plaintiffs Yick’s Fourth Set of Interrogatories,
served on Plaintiffs January 2, 2024, along with associated exhibits and verification,
which were marked Exhibits 143, 143-09, 143-10, and 143-11 to the Lennon 30(b)(6)
Deposition.
95.
Attached hereto as PX 94 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00570335-37, which was
marked Exhibit 233 to the Garfield Deposition and Exhibit 158 to the Johnson
Deposition.
96.
Attached hereto as PX 95 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00429789-95, which was
marked Exhibit 170 to the Johnson Deposition.
97.
Attached hereto as PX 96 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00706496-97, which was
marked Exhibit 420 to the Moynihan Deposition.
98.
Attached hereto as PX 97 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00876417, which was
marked Exhibit 319 to the Ahmad Deposition.
99.
Attached hereto as PX 98 is a true and correct copy of a document produced
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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by the Bank in this action Bates-stamped BANA_EDD_MDL-00293818-21, which was
marked Exhibit 89 to the Letson 30(b)(6) Deposition.
100. Attached hereto as PX 99 is a true and correct copy of a document produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00162397, which was
marked Exhibit 361 to the Fox Deposition.
101. Attached hereto as PX 100 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00570351, which
was marked Exhibit 371 to the Ehresman Deposition.
102. Attached hereto as PX 101 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00497802-04.
103. Attached hereto as PX 102 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00878451-52,
which was marked Exhibit 427 to the Moynihan Deposition.
104. Attached hereto as PX 103 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00882977-79,
which was marked Exhibit 425 to the Moynihan Deposition.
105. Attached hereto as PX 104 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00882712-19,
which was marked Exhibit 426 to the Moynihan Deposition.
106. Attached hereto as PX 105 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-100634-79,
which was marked Exhibit 17 to the Daniels 30(b)(6) Deposition.
107. Attached hereto as PX 106 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00158953, which
was marked Exhibit 18 to the Daniels 30(b)(6) Deposition.
108. Attached hereto as PX 107 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00556536-37,
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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which was marked Exhibit 92 to the Letson 30(b)(6) Deposition.
109. Attached hereto as PX 108 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00143391-93,
which was marked Exhibit 94 to the Letson 30(b)(6) Deposition.
110. Attached hereto as PX 109 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00076993-95,
which was marked Exhibit 373 to the Ehresman Deposition.
111. Attached hereto as PX 110 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00510141-48,
which was marked Exhibit 137 to the Lennon 30(b)(6) Deposition.
112. Attached hereto as PX 111 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00077127-28,
which was marked Exhibit 334 to the Ahmad Deposition.
113. Attached hereto as PX 112 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00090640-47,
which was marked Exhibit 61 to the Martin 30(b)(6) Deposition.
114. Attached hereto as PX 113 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00107261-66,
which was marked Exhibit 62 to the Martin 30(b)(6) Deposition.
115. Attached hereto as PX 114 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00107327-35,
which was marked Exhibit 63 to the Martin 30(b)(6) Deposition.
116. Attached hereto as PX 115 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00090683-86,
which was marked Exhibit 64 to the Martin 30(b)(6) Deposition.
117. Attached hereto as PX 116 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00273305-07,
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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which was marked Exhibit 91 to the Letson 30(b)(6) Deposition.
118. Attached hereto as PX 117 is a true and correct copy of an article published
by CalMatters on November 20, 2020 titled “How Bank of America Helped Fuel
California’s Unemployment Meltdown.”
119. Attached hereto as PX 118 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
BANA_EDD_MDL-00888326, which was transcribed as described in the Aristedes
Declaration.
120. Attached hereto as PX 119 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
BANA_EDD_MDL-00887608, which was transcribed as described in the Aristedes
Declaration.
121. Attached hereto as PX 120 is a true and correct copy of a transcript of an
excerpt of an audio file produced by the Bank in this action Bates-stamped
BANA_EDD_MDL-00887001, which was transcribed as described in the Aristedes
Declaration.
122. Attached hereto as PX 121 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00058621-28,
which was marked Exhibit 434 to the Moynihan Deposition.
123. Attached hereto as PX 122 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00105556, which
was marked Exhibit 429 to the Moynihan Deposition.
124. Attached hereto as PX 123 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00373787-88,
which was marked Exhibit 430 to the Moynihan Deposition.
125. Attached hereto as PX 124 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00188717-18,
Case 3:21-md-02992-GPC-MSB Document 634 Filed 01/09/26 PageID.51580 Page
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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which was marked Exhibit 431 to the Moynihan Deposition.
126. Attached hereto as PX 125 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00105900, which
was marked Exhibit 432 to the Moynihan Deposition.
127. Attached hereto as PX 126 is a true and correct copy of the declaration of
class representative Plaintiff Kuang Ting Chong.
128. Attached hereto as PX 127 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00870275-76,
which was marked Exhibit 435 to the Moynihan Deposition.
129. Attached hereto as PX 128 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00284155, which
was marked Exhibit 436 to the Moynihan Deposition.
130. Attached hereto as PX 129 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00041664, which
was marked Exhibit 437 to the Moynihan Deposition.
131. Attached hereto as PX 130 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00027088-89,
which was marked Exhibit 438 to the Moynihan Deposition.
132. Attached hereto as PX 131 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00041705, which
was marked Exhibit 439 to the Moynihan Deposition.
133. Attached hereto as PX 132 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00027124, which
was marked Exhibit 441 to the Moynihan Deposition.
134. Attached hereto as PX 133 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00041795, which
was marked Exhibit 442 to the Moynihan Deposition.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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135. Attached hereto as PX 134 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00027231-32,
which was marked Exhibit 443 to the Moynihan Deposition.
136. Attached hereto as PX 135 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00029021-22,
which was marked Exhibit 444 to the Moynihan Deposition.
137. Attached hereto as PX 136 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00090721-26,
which was marked Exhibit 59 to the Martin 30(b)(6) Deposition.
138. Attached hereto as PX 137 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00452786-802,
which was marked Exhibit 58 to the Martin 30(b)(6) Deposition.
139. Attached hereto as PX 138 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00874570-71.
140. Attached hereto as PX 139 is a true and correct copy excerpts of Revised
Exhibit 2 to Bank of America’s Response to Plaintiffs’ Interrogatories.
141. Attached hereto as PX 140 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00571307-10.
142. Attached hereto as PX 141 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00417487-90,
which was marked Exhibit 93 to the Letson 30(b)(6) Deposition.
143. Attached hereto as PX 142 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00845906-08,
which was marked Exhibit 395 to the Simpson Deposition.
144. Attached hereto as PX 143 is a true and correct copy of excerpts of a report
titled “Employment Development Department Strike Team Detailed Assessment &
Recommendations,” which was marked Exhibit 36 to the Chestnut 30(b)(6) Deposition.
Case 3:21-md-02992-GPC-MSB Document 634 Filed 01/09/26 PageID.51582 Page
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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145. Attached hereto as PX 144 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00071396-403,
which was marked Exhibit 249 to the Garfield Deposition.
146. Attached hereto as PX 145 is a true and correct copy of excerpts of
Defendant’s Responses and Objections to Plaintiffs’ Fifth Set of Interrogatories.
147. Attached hereto as PX 146 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00405158-60,
which was marked Exhibit 400 to the Simpson Deposition.
148. Attached hereto as PX 147 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00169898-99,
which was marked Exhibit 384 to the Simpson Deposition.
149. Attached hereto as PX 148 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-000417555-58.
150. Attached hereto as PX 149 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00631444-46.
151. Attached hereto as PX 150 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00125919-23,
which was marked Exhibit 60 to the Martin 30(b)(6) Deposition.
152. Attached hereto as PX 151 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00172236-44.
153. Attached hereto as PX 152 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00118438, which
was marked Exhibit 105 to the Golden 30(b)(6) Deposition.
154. Attached hereto as PX 153 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00106092-94,
which was marked Exhibit 104 to the Golden 30(b)(6) Deposition.
155. Attached hereto as PX 154 is a true and correct copy of a document
Case 3:21-md-02992-GPC-MSB Document 634 Filed 01/09/26 PageID.51583 Page
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00876475-76,
which was marked Exhibit 369 to the Ehresman Deposition.
156. Attached hereto as PX 155 is a true and correct copy of documents produced
by the Bank in this action Bates-stamped BANA_EDD_MDL-00411205, -00556094, -
00556122, -00556152, -00556324, -00558991, -00558996, -00559094, and 00559101
and documents produced by the Plaintiff in this action Bates-stamped PLFF00000008
and Yuan_A_0000003-4.
157. Attached hereto as PX 156 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00719115, which
was marked Exhibit 103 to the Golden 30(b)(6) Deposition.
158. Attached hereto as PX 157 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00881851-54,
which was marked Exhibit 407 to the Montag Deposition.
159. Attached hereto as PX 158 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00090040-47.
160. Attached hereto as PX 159 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00013086-93.
161. Attached hereto as PX 160 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00013096-106.
162. Attached hereto as PX 161 is a true and correct copy of a press release
published in Business Wire on September 30, 2014 titled “Bank of America Begins
Rollout of Chip Debit Cards,” which was marked Exhibit 44 to the Martin 30(b)(6)
Deposition.
163. Attached hereto as PX 162 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-000455617-19.
164. Attached hereto as PX 163 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00205593-97.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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165. Attached hereto as PX 164 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00370150-55,
which was marked Exhibit 46 to the Martin 30(b)(6) Deposition.
166. Attached hereto as PX 165 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00463207-10.
167. Attached hereto as PX 166 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL- 00228914-15.
168. Attached hereto as PX 167 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00495777-89,
which was marked Exhibit 15 to the Joseph Deposition.
169. Attached hereto as PX 168 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00004996-5020.
170. Attached hereto as PX 169 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00082602-06.
171. Attached hereto as PX 170 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00170413-18.
172. Attached hereto as PX 171 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00167019-24.
173. Attached hereto as PX 172 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00401305-12.
174. Attached hereto as PX 173 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00123235-36,
which was marked Exhibit 49 to the Martin 30(b)(6) Deposition.
175. Attached hereto as PX 174 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00154042-44.
176. Attached hereto as PX 175 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00166345.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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177. Attached hereto as PX 176 is a true and correct copy of a document
produced by EDD in this action Bates-stamped EDD002375-79, which was marked
Exhibit 401 to the Simpson Deposition.
178. Attached hereto as PX 177 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00104749-50,
which was marked Exhibit 398 to the Simpson Deposition.
179. Attached hereto as PX 178 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00163307-08,
which was marked Exhibit 52 to the Martin 30(b)(6) Deposition.
180. Attached hereto as PX 179 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00417363.
181. Attached hereto as PX 180 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00297295, which
was marked Exhibit 262 to the Garfield Deposition.
182. Attached hereto as PX 181 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00351839-40,
which was marked Exhibit 47 to the Martin 30(b)(6) Deposition.
183. Attached hereto as PX 182 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00116001-02,
which was marked Exhibit 39 to the Chestnut 30(b)(6) Deposition.
184. Attached hereto as PX 183 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00406993-7019.
185. Attached hereto as PX 184 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00104742-46.
186. Attached hereto as PX 185 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00124142, which
was marked Exhibit 40 to the Chestnut 30(b)(6) Deposition.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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187. Attached hereto as PX 186 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00352396-97,
which was marked Exhibit 51 to the Martin 30(b)(6) Deposition.
188. Attached hereto as PX 187 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00357755-56.
189. Attached hereto as PX 188 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00353033-35.
190. Attached hereto as PX 189 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00678774-75,
which was marked Exhibit 23 to the Joseph Deposition.
191. Attached hereto as PX 190 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00166417-19.
192. Attached hereto as PX 191 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00297351-52.
193. Attached hereto as PX 192 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00082642-50.
194. Attached hereto as PX 193 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00431011-14.
195. Attached hereto as PX 194 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00218256.
196. Attached hereto as PX 195 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00166407-09.
197. Attached hereto as PX 196 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00632771-74.
198. Attached hereto as PX 197 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00172469-73,
which was marked Exhibit 53 to the Martin 30(b)(6) Deposition.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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199. Attached hereto as PX 198 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00171972-73.
200. Attached hereto as PX 199 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00570314-15,
which was marked Exhibit 146 to the Johnson Deposition.
201. Attached hereto as PX 200 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00057504-06,
which was marked Exhibit 45 to the Martin 30(b)(6) Deposition.
202. Attached hereto as PX 201 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00059312-18.
203. Attached hereto as PX 202 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00706212-14,
which was marked Exhibit 300 to the Ahmad Deposition.
204. Attached hereto as PX 203 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00140411-16,
which was marked Exhibit 217 to the Garfield Deposition.
205. Attached hereto as PX 204 is a true and correct copy of excerpts from
Defendant’s Second Set of Responses and Objections to Plaintiffs’ Seventh Set of
Interrogatories.
206. Attached hereto as PX 205 is a true and correct copy of excerpts from
Revised Exhibit 3 to Defendant’s Response to Plaintiffs’ Interrogatories.
207. Attached hereto as PX 206 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00087749-51,
which was marked Exhibit 74 to the Letson 30(b)(6) Deposition.
208. Attached hereto as PX 207 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00125863-64,
which was marked Exhibit 86 to the Letson 30(b)(6) Deposition.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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209. Attached hereto as PX 208 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00162408, which
was marked Exhibit 239 to the Garfield Deposition.
210. Attached hereto as PX 209 is a true and correct copy of the Preliminary
Injunction in Yick v. Bank of America, Case No. 21-cv-00376-VC, filed on June 2, 2021.
211. Attached hereto as PX 210 is a true and correct copy of the Order
Re Preliminary Injunction in Yick v. Bank of America, Case No. 21-cv-00376-VC, filed
on May 17, 2021.
212. Attached hereto as PX 211 is a true and correct copy of the Consumer
Financial Protection Bureau Consent Order against Bank of America, N.A., File No.
2022-CFPB-0004, filed on July 14, 2022.
213. Attached hereto as PX 212 is a true and correct copy of the Office of the
Comptroller of the Currency Consent Order against Bank of America, N.A., File No. AA-
ENF-2022-21, filed on July 14, 2022.
214. Attached hereto as PX 213 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00102554-77,
which was marked Exhibit 132 to the Lennon 30(b)(6) Deposition.
215. Attached hereto as PX 214 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_ EDD_MDL-00003887-911,
which was marked Exhibit 182 to the Johnson Deposition.
216. Attached hereto as PX 215 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00592324-30,
which was marked Exhibit 80 to the Letson 30(b)(6) Deposition.
217. Attached hereto as PX 216 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00006482-535,
which was marked Exhibit 181 to the Johnson Deposition.
218. Attached hereto as PX 217 is a true and correct copy of a document
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00663724-45,
which was marked Exhibit 14 to the Daniels 30(b)(6) Deposition.
219. Attached hereto as PX 218 is a true and correct copy of excerpts of a
document produced by the Bank in this action Bates-stamped BANA_EDD_MDL-
00013111-63, which was marked Exhibit 118 to the Golden 30(b)(6) Deposition.
220. Attached hereto as PX 219 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00205620-29.
221. Attached hereto as PX 220 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00012816-74.
222. Attached hereto as PX 221 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-0087742-43,
which was marked Exhibit 81 to the Letson 30(b)(6) Deposition.
223. Attached hereto as PX 222 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00426935-39,
which was marked Exhibit 241 to the Garfield Deposition.
224. Attached hereto as PX 223 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00001199.
225. Attached hereto as PX 224 is a true and correct copy of excerpts from a
document titled, “Response to State of California Electronic Benefits Payment |
Solicitation RFP No. 65466, Vol I – EBP Service Proposal MASTER COPY,” dated July
10, 2015, which was marked Exhibit 26 to the Chestnut 30(b)(6) Deposition.
226. Attached hereto as PX 225 is a true and correct copy of excerpts from a
document titled, "The US Contact Center Decision-Makers Guide 2021.”
227. Attached hereto as PX 226 is a true and correct copy of the Declaration of
class representative Plaintiff Vanessa Rivera (“Rivera Declaration”).
228. Attached hereto as PX 227 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00159489-94.
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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229. Attached hereto as PX 228 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00037137.
230. Attached hereto as PX 229 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-0057488-90,
which was marked Exhibit 294 to the Holt Deposition.
231. Attached hereto as PX 230 is a true and correct copy of excerpts from the
transcript of Defendant’s deposition of Azuri Moon, taken on February 27, 2024 (“Moon
Deposition”).
232. Attached hereto as PX 231 is a true and correct copy of excerpts from the
transcript of Defendant’s deposition of Roland Oosthuizen, taken on March 29, 2024
(“Oosthuizen Deposition”).
233. Attached hereto as PX 232 is a true and correct copy of excerpts from the
transcript of Defendant’s deposition of J. Daniel Kreis, taken on May 5, 2025 (“Kreis
Deposition”).
234. Attached hereto as PX 233 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00076931-47,
which was marked Exhibit 280 to the Holt Deposition.
235. Attached hereto as PX 234 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00426660, which
was marked Exhibit 312 to the Montag Deposition.
236. Attached hereto as PX 235 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00169902-04,
which was marked Exhibit 274 to the Holt Deposition.
237. Attached hereto as PX 236 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00102786-87,
which was marked Exhibit 269 to the Holt Deposition.
238. Attached hereto as PX 237 is a true and correct copy of a document
Case 3:21-md-02992-GPC-MSB Document 634 Filed 01/09/26 PageID.51591 Page
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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produced by the Bank in this action Bates-stamped BANA_EDD_MDL-0070242-47,
which was marked Exhibit 301 to the Ahmad Deposition.
239. Attached hereto as PX 238 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00491410-14,
which was marked Exhibit 348 to the Ramirez Deposition.
240. Attached hereto as PX 239 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00127312-15,
which was marked Exhibit 349 to the Ramirez Deposition.
241. Attached hereto as PX 240 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00200628-32,
which was marked Exhibit 250 to the Garfield Deposition.
242. Attached hereto as PX 241 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00881951-68,
which was marked Exhibit 414 to the Moynihan Deposition.
243. Attached hereto as PX 242 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00293818-21,
which was marked Exhibit 423 to the Moynihan Deposition.
244. Attached hereto as PX 243 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00105271-72,
which was marked Exhibit 428 to the Moynihan Deposition.
245. Attached hereto as PX 244 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00127417-20,
which was marked Exhibit 108 to the Golden Deposition.
246. Attached hereto as PX 245 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00870098-101.
247. Attached hereto as PX 246 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00371949-50,
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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which was marked Exhibit 306 to the Montag Deposition and Exhibit 387 to the Simpson
Deposition.
248. Attached hereto as PX 247 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00372031-46,
which was marked Exhibit 303 to the Ahmad Deposition.
249. Attached hereto as PX 248 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00417271-72,
which was marked Exhibit 174 to the Johnson Deposition.
250. Attached hereto as PX 249 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00426935-39,
which was marked Exhibit 372 to the Ehresman Deposition.
251. Attached hereto as PX 250 is a true and correct copy of Plaintiff
Oosthuizen’s Supplemental Objections and Responses to Bank of America, N.A.’s First
Set of Interrogatories.
252. Attached hereto as PX 251 is a true and correct copy of Plaintiff Koole’s
Supplemental Objections and Responses to Bank of America, N.A.’s First Set of
Interrogatories.
253. Attached hereto as PX 252 is a true and correct copy of Plaintiff Moon’s
Supplemental Objections and Responses to Bank of America, N.A.’s First Set of
Interrogatories.
254. Attached hereto as PX 253 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00674360-64.
255. Attached hereto as PX 254 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00169847-51,
which was marked Exhibit 76 to Letson’s 30(b)(6) Deposition.
256. Attached hereto as PX 255 is a true and correct copy of Plaintiff Kuang Ting
Chong’s Supplemental Objections and Responses to Bank of America, N.A.’s First Set of
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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Interrogatories.
257. Attached hereto as PX 256 is a true and correct copy of Plaintiff Stephanie
Moore’s Supplemental Objections and Responses to Bank of America, N.A.’s First Set of
Interrogatories.
258. Attached hereto as PX 257 is a true and correct copy of Plaintiff Alex
Yuan’s Supplemental Objections and Responses to Bank of America, N.A.’s First Set of
Interrogatories.
259. Attached hereto as PX 258 is a true and correct copy of a letter dated
January 26, 2021 providing Notice of Violations of The California Consumer Privacy Act
on behalf of Roland Oosthuizen and Rosemary Mathews.
260. Attached hereto as PX 259 is a true and correct copy of Plaintiff Lindsay
McClure’s Supplemental Objections and Responses to Bank of America, N.A.’s First Set
of Interrogatories.
261. Attached hereto as PX 260 is a true and correct copy of Plaintiff Vanessa
Rivera’s Supplemental Objections and Responses to Bank of America, N.A.’s First Set of
Interrogatories.
262. Attached hereto as PX 261 is a true and correct copy of excerpts from
BANA’s Verified Responses & Objections to Plaintiffs Third Set of Interrogatories,
which was marked Exhibit 139 to the Lennon 30(b)(6) Deposition.
263. Attached hereto as PX 262 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00087775-78,
which was marked Exhibit 286 to the Holt Deposition.
264. Attached hereto as PX 263 is a true and correct copy of the Expert Class
Certification Report of Greg J. Regan, CPA/CFF, CFE, dated August 29, 2024, and
appendices thereto.
265. Attached hereto as PX 264 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00090695-98,
Case 3:21-md-02992-GPC-MSB Document 634 Filed 01/09/26 PageID.51594 Page
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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which was marked Exhibit 55 to the Martin 30(b)(6) Deposition.
266. Attached hereto as PX 265 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00169948-52.
267. Attached hereto as PX 266 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00159382-83,
which was marked Exhibit 375 to the Ehresman Deposition.
268. Attached hereto as PX 267 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00077066-69,
which was marked Exhibit 377 to the Ehresman Deposition.
269. Attached hereto as PX 268 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00171972-73.
270. Attached hereto as PX 269 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00698454-55,
which was marked Exhibit 21 to the Joseph Deposition.
271. Attached hereto as PX 270 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00883605-32,
which was marked Exhibit 445 to the Moynihan Deposition.
272. Attached hereto as PX 271 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00874614-15,
which was marked Exhibit 446 to the Moynihan Deposition.
273. Attached hereto as PX 272 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00874614-15,
which was marked Exhibit 419 to the Moynihan Deposition.
274. Attached hereto as PX 273 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00127437-41,
which was marked Exhibit 351 to the Ramirez Deposition.
275. Attached hereto as PX 274 is a true and correct copy of a document
Case 3:21-md-02992-GPC-MSB Document 634 Filed 01/09/26 PageID.51595 Page
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00062175-82,
which was marked Exhibit 352 to the Ramirez Deposition.
276. Attached hereto as PX 275 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00646320-35,
which was marked Exhibit 353 to the Ramirez Deposition.
277. Attached hereto as PX 276 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00714619-21,
which was marked Exhibit 359 to the Fox Deposition.
278. Attached hereto as PX 277 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00347350.
279. Attached hereto as PX 278 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00087718-20,
which was marked Exhibit 188 to the Schwartz Deposition.
280. Attached hereto as PX 279 is a true and correct copy of the Office of the
Comptroller of the Currency (“OCC”) Civil Money Penalty Order against Bank of
America, N.A., File No. AAENF-2022-22, filed on July 14, 2022.
281. Attached hereto as PX 280 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00169161, which
was marked Exhibit 243 to the Garfield Deposition.
282. Attached hereto as PX 281 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00071120-25,
which was marked Exhibit 248 to the Garfield Deposition.
283. Attached hereto as PX 282 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00371656-57.
284. Attached hereto as PX 283 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00631430-31.
285. Attached hereto as PX 284 is a true and correct copy of excerpts from
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
Case No.: 3:21-md-02992-GPC-MSB
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BANA's Verified Revised Second Supplemental Responses & Objections to Plaintiffs
First Set of Interrogatories, which was marked Exhibit 136 to the Lennon 30(b)(6)
Deposition.
286. Attached hereto as PX 285 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-0057837-78.
287. Attached hereto as PX 286 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00719116.
288. Attached hereto as PX 287 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00102937.
289. Attached hereto as PX 288 is a true and correct copy of excerpts from a
document titled, "The US Contact Center Decision-Makers Guide 2021.”
290. Attached hereto as PX 289 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00406128-30,
which was marked Exhibit 96 to the Letson 30(b)(6) Deposition.
291. Attached hereto as PX 290 is a true and correct copy of excerpts from
BANA's Verified Responses & Objections to Plaintiffs’ Fourth Set of Interrogatories,
which was marked Exhibit 143 to the Lennon 30(b)(6) Deposition.
292. Attached hereto as PX 291 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00012790, which
was marked Exhibit 15 to the Daniels 30(b)(6) Deposition.
293. Attached hereto as PX 292 is a true and correct copy of a document
produced by the Bank in this action Bates-stamped BANA_EDD_MDL-00874835,
00885638-39, which was marked Exhibit 271 to the Holt Deposition and Exhibit 185 to
the Schwartz Deposition.
294. Attached hereto as PX 293 is a true and correct copy of the Declaration of
class representative Plaintiff Stephanie Moore (“Moore Declaration”).
295. Attached hereto as PX 294 is a true and correct copy of the Declaration of
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
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proposed class representative Plaintiff Alex Yuan (“Yuan Declaration”).
296. Attached hereto as PX 295 is a true and correct copy of the Declaration of
class representative Plaintiff Candace Koole (“Koole Declaration”).
297. Attached hereto as PX 296 is a true and correct copy of the Declaration of
class representative Plaintiff Azuri Moon (“Moon Declaration”).
298. Attached hereto as PX 297 is a true and correct copy of an excerpt of a
document produced by the Bank in this action Bates-stamped BANA_EDD_MDL-
00060339.
299. Attached hereto as PX 298 is a true and correct copy of the Declaration of
Kelly Koehnen Aristides in Support of Plaintiffs’ Opposition to Motion for Partial
Summary Judgment.
300. Attached hereto as PX 299 is a true and correct copy of the Declaration of
class representative Lindsey McClure (“McClure Declaration”).
I declare under penalty of perjury that that the foregoing is true and correct.
Executed this 9th day of January, 2026 in Burlingame, California.
s/ Connie K. Chan
Connie K. Chan
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DECL. OF CONNIE K. CHAN IN OPP. TO MOT. FOR PARTIAL SUMMARY
JUDGMENT
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 9, 2026
/s/ Brian Danitz
Brian Danitz
Case 3:21-md-02992-GPC-MSB Document 634 Filed 01/09/26 PageID.51599 Page
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