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JAMES W. MCGARRY (pro hac vice)
JMcGarry_(a),zoodwinlaw.com
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GOODWJN1>ROCTER LLP
100 Northern Avenue
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Boston, MA 02210
Tel.:+ 1 617 570 1000
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Fax:+16175231231
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SABRINA M. ROSE-SMITH (pro hac vice)
SRoseSmith(ci),zoodwinlaw.com
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MATTHEWT. RIFFEE (pro hac vice)
MRiffee(ci),g_o_odwinlaw. com
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GOODWIN PROCTER LLP
1900 N Street NW
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Washing!on, DC 20036
Tel.: + 1 202 346 4000
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Fax:+ 1 202 346 4444
1 o Attorneys for Defendant
BANK OF AMERICA, N.A.
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
SAN DIEGO DIVISION
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IN RE: BANK OF AMERICA
CALIFORNIA UNEMPLOYMENT
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BENEFITS LITIGATION
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RUIZ DECL. ISO MOT. FOR PROTECTIVE ORDER
Case No. 21-MD-02992-GPC-MSB
DECLARATION OF STACEY
RUIZ IN SUPPORT OF
DEFENDANT'S MOTION FOR A
PROTECTIVE ORDER
CASE No. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 455 Filed 04/11/25 PageID.26914 Page
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I, Stacey Ruiz, state and declare as follows:
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1.
I am an Assistant Vice President, for Bank of America, N.A. ("BANA")
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in the above-captioned lawsuit.
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2.
In my capacity as Assistant Vice President, I have come to know
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BANA's internal processes and procedures. I am also familiar with BANA's record
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keeping processes and I have access to the business records maintained by BANA,
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including those in connection with its employees (the "BANA Business Records").
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My testimony in this declaration is on information and belief based on my review of
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certain BANA Business Records, my review of transcripts taken in this case, and
1 O public news articles, which reflect the employment history of the individuals
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described herein. If called upon to do so, I could and would competently testify
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thereto.
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3.
I make this declaration in support of BANA's Motion for a Protective
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Order.
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4.
Bank of America, N.A. ("BANA") is a wholly owned subsidiary of
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Bank of America Corporation ("BAC"). BAC is the holding company for 57
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companies, including operations in all 50 states of the U.S and more than 35
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countries, with more than 213,000 employees.
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5.
Brian Moynihan has been the Chair ofBAC since October 2014 and has
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been Chief Executive Officer ("CEO") since 2010.
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6.
Thomas Montag was BANA's second-in-line executive, with the title of
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Chief Operating Officer ("COO") and President of Global Banking and Markets,
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until December 2021, and is now the CEO of Rubicon Carbon.
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Employment of Certain Individuals at BANA During 2020-2021
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7.
Shane Daniels was Head of Small Business Claims and Operations.
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8.
Robert Chestnut was a Regional Executive in Relationship
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Management.
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9.
William Matthew Martin was a Senior Vice President in Fraud
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RUIZ DECL. ISO MOT. FOR PROTECTIVE ORDER
CASE No. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 455 Filed 04/11/25 PageID.26915 Page
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Management.
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Michael Letson was a Managing Director of Global Financial Crimes
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("GFC").
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William Golden was an Operations Managing Director.
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Jennifer Lennon was a Program Management Senior Vice President.
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Renee Johnson led the Consumer Claims Resolution and Recovery
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group.
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Ryan Schwartz was a GFC specialist. In that role, Mr. Schwartz was
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four reporting structures beneath the CEO.
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Bradley Garfield was Head of Commercial Cards Product Management.
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Anne Holt was Director of GFC.
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Faiz Ahmad was
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Melissa Ramirez was a business banking operations executive m
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Commercial Card Fulfillment, Service, & Operations.
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William Fox was the GFC Global Head. Prior to joining BANA, he
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served as the former Director of the Financial Crimes Enforcement Network.
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Jennifer Ehresman was Head of Consumer Client Protection.
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Paul Simpson was Managing Director of Business Executive
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Operations.
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I declare under penalty of perjury under the laws of the United States that the
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foregoing
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true
and
correct.
Executed
on April
11,
2025,
m
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K; a /ID
------t:~A __ _
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By: ~?~ -ix r
.
s
BANK OF A
RICA, N.A.
Name: Stacey Ruiz
Title: Assistant Vice President
Date: April 11, 2025
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R UIZ D ECL. ISO MOT. FOR PROTECTIVE ORDER
CASE No. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 455 Filed 04/11/25 PageID.26916 Page
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