Declaration Of Jeff Newcomb, Doc. 33-1 — D. Colo., CourtListener docket 239393

Date: 2025-04-28

Summary

Document 33-1 in Case No. 1:24-cv-03390-RMR in the U.S. District Court for the District of Colorado, filed April 28, 2025, a filing of exhibits. Exhibit A is the Declaration of Jeff Newcomb, a Branch Manager in the Division of Unemployment Insurance of the Colorado Department of Labor and Employment, stating that the Division's records show no request for disability accommodations by the claimant. Exhibit B, a declaration by a Division program manager, describes the MyUI+ online portal, the document submission form and an escalation feature available as of April 2, 2025. Exhibit C, a declaration by a Benefit Payment Control team lead, describes program integrity holds and the history of the claimant's claims effective March 5, 2023 and February 2, 2025. The filing ends with a call log with entries from February, March and April 2025.

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A
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EXHIBIT A
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DECLARATION OF JEFF NEWCOMB

I, Jeff Newcomb, being over age 18 and of sound mind do state as follows:

1. I am employed by the Colorado Department of Labor and Employment (“CDLE”) in the
Division of Unemployment Insurance (“the Division”). I have worked for the Division
for the past 18 years. My current title is Branch Manager – Unemployment Insurance
Customer Services.

2. In my role, I provide strategic oversight for the Division’s benefits customer service
branch. I ensure we meet customer needs while following federal and state laws and
regulations.

3. The Division provides unemployment claimants with reasonable accommodations, as
required by the Americans with Disabilities Act. Any accommodation requests are
brought to me to ensure relevant policies, procedures, regulations, and laws are followed.

4. A claimant can request an accommodation at any point when speaking with any call
center agent.

5. A claimant can also request an accommodation during an in-person appointment, which
can be requested online.

6. Joshua Abrams currently has an active unemployment claim from 2025 and previously
had a claim in 2023. This claim ended in the last quarter of 2023 when Mr. Abrams
returned to work.

7. I have reviewed Mr. Abrams’ claim file and documentation concerning his contacts with
the Division.

8. Mr. Abrams had an in-person appointment concerning the 2023 unemployment claim on
March 30, 2023.

9. Mr. Abrams has spoken with call center agents multiple times in 2023 and in 2025.

10. From my review of the Division’s records, at no time did Mr. Abrams request
accommodations for any disability.

I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true
and correct to the best of my knowledge.

Executed this 18th day of April 2025.

____________________________________

Jeff Newcomb
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EXHIBIT B
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DECLARATION OF BRANDON MCCLURE

I, Brandon McClure, being over age 18 and of sound mind do state as follows:

2. Unemployment claimants have the ability to access information about their
unemployment claim through an online portal called MyUI+.

3. As program manager, I work with the Division’s vendor that develops the MyUI+ system
on incidents concerning MyUI+ and any changes to MyUI+ that are needed to resolve
recurring issues and enhance the system for Division staff and claimants.

4. The landing page of MyUI+ shows claimants a menu of options including:

a. My Home Page;

b. My Inbox;

c. My Claim Status;

d. View Correspondences

e. View and Maintain Account Information.

5. The View and Maintain Account Information menu option expands and shows claimants
additional choices:

a. Issues and Determinations;

b. Contact Information;

c. Employment History;

d. General Information;

e. Payment History;

f. Payment Method Options and Tax Information.

6. When issues arise that could affect payment of an unemployment claim, the claimant
receives a notification via email directing them to log into MyUI+.

7. After logging into MyUI+, claimants can click on the relevant menu item to address the
issues preventing the claim from being processed and provide the information necessary
to resolve the issue. Claimants can add written notes in the system and upload documents.

1
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8. Claimants can also upload documents without logging into MyUI+ through the Division’s
“document submission form.” The link for this form is located here:
https://cdle.colorado.gov/unemployment/contact-us.

9. Claimants can upload the following types of documents through this form:

a. “Benefit Investigation form for the Benefit Accuracy Measurement team;”

b. “Incarceration Investigation form for the Benefit Payment Control team;”

c. “Identity documentation requested by the division;”

d. “Form to submit an appeal regarding my Unemployment Insurance claim;”

e. “Supporting documentation for an already scheduled appeal hearing;”

f. “Response to a questionnaire or message I received through MyUI+.”

10.Claimants must select from the above list to ensure the document is directed to the
correct team within the Division.

11.The Division has FAQs and tutorials on how to use MyUI+ available online at
https://cdle.colorado.gov/myui-plus.

12.As of April 2, 2025, MyUI+ has an escalation feature, which becomes available to a
claimant if issues are not resolved within a time period that varies depending on the
specific issue pending. If a claimant selects the escalation button, it will immediately
notify the appropriate team of the escalation so the issue can be prioritized.

13.The Division does not have an email address to which claimants can direct all inquiries.
The Division did previously have an email account for this purpose, but the volume of
inquiries was unmanageable. If the Division were to reactivate that account, it could not
reasonably respond to inquiries within three days due to the high volume of written
inquiries coming in on top of phone calls.

14.The Division cannot unilaterally make changes to the MyUI+ system. The Division
would have to file a change task with the vendor and hold design sessions with the
vendor to determine functionality and location of the system change. The vendor would
then need time to develop and test the change. After vendor testing is complete, the
Division would test the change before it could be deployed for public use. The Division is
currently engaging in this process for several system enhancements. These enhancements
are expected to take the remainder of 2025 to complete. Any additional change would
take approximately 6-9 months to complete after the in-process enhancements are
complete.

15.Joshua Abrams currently has an active unemployment claim and is receiving benefits. He
also had an active claim in 2023.

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16. I have reviewed his claim file, including activity in his online portal.

17. Mr. Abrams has successfully used the online portal and communicated with the Division
online:

a. On March 21, 2023, the Division emailed Mr. Abrams regarding an identity
verification issue and other issues with his claim. Mr. Abrams requested an
in-person appointment on this date. That appointment occurred on March 30,
2023.

b. On March 15, 2025, Mr. Abrams was able to upload documents into the portal in
response to a program integrity hold.

c. The integrity hold was lifted on March 17, 2025, and Mr. Abrams received
unemployment benefits on March 20, 2025.

d. On April 11, 2025, Mr. Abrams updated his contact information.

I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true
and correct to the best of my knowledge.

Executed this 18th day of April, 2025.

___________________________________________

Brandon McClure

3
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C
EXHIBIT C
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DECLARATION OF GUADALUPE DIAZ

I, Guadalupe Diaz, being over age 18 and of sound mind do state as follows:

1. I am employed by the Colorado Department of Labor and Employment (“CDLE”) in the
Division of Unemployment Insurance (“the Division”). I have worked for the Division
for the past ten years. My current title is Labor and Employment Specialist III, Benefit
Payment Control.

2. In my role, I am team lead of the Invalid Claims Team within the Benefit Payment
Control section. I help oversee program integrity and assist deputies in reviewing cases of
potential fraud and referring matters for criminal prosecution. I train and coach staff in
the Benefits section and Invalid Claims team. I review news, information, and trends
from other states that may help identify potential new sources or types of fraud claims. I
assure that escalations of program integrity issues are promptly assigned to a member of
the Invalid Claims team for processing.

3. During the COVID-19 pandemic, and particularly from 2020 to 2023, Colorado and other
states experienced a significant uptick in the volume of fraudulent claims for
unemployment insurance benefits and for extended pandemic benefits provided by the
United States Department of Labor. The Division has received millions of fraudulent
claims since the COVID-19 pandemic began in 2020.

4. On or about March 15, 2020, the Division adopted program integrity measures to ensure
that benefits were paid correctly and to avoid payment of fraudulent claims, per USDOL.
The program integrity process reviews and compares available information from a variety
of sources, including claimants and employers, to flag potential discrepancies that could
indicate a fraudulent claim.

5. Depending on the severity of the flagged issue(s), the claims system will establish a
program integrity hold, which prevents the payment of benefits until further information
can be requested, received, and reviewed by the Division.

6. If the system flags a claim, a program integrity pending issue (holding payment) is placed
on the claim immediately and automatically sends a fact-finding request to the claimant,
and the claimant receives an alert regarding the fact-finding. The claimant is given seven
days to respond to a list of questions and provide personally identifying information,
including but not limited to social security number, driver’s license number, passport( as
another alternative of identification if the claimant does not have an ID or driver’s
license) proof of address or a utility bill, a “selfie” photograph of the claimant, a “selfie”
holding their driver’s license or ID, and lastly a eligible copy of the bank account
statement associated with the claim not older than 90 days or their US Bank Reliacard
card statement.

7. If the Division receives the requested information from a claimant within seven days, the
information is reviewed (Fact-finding and documents) and verified by the deputy, and a
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decision is made whether to release the hold, to seek further information, or to disqualify
the claimant.

8. If the Division does not receive the requested information within seven days of sending
the factfinding, the system sends a “reporting requirement disqualification” to the
claimant, which informs the claimant that they have been disqualified for failing to
provide information and provides notice of the right to appeal that decision within 20
days the decision was mailed.

9. If the deputy determines a program integrity hold should be removed, the hold is
removed, and the claimant is notified of the decision. The claim is then released for
adjudication of the separation(s) pending on the claim.

Mr. Abrams’ 2023 Claim for Benefits

10. Joshua Abrams has filed two claims for unemployment benefits with the Division to date.
The first claim was effective March 5, 2023. The second claim was effective February 2,
2025.

11. Mr. Abrams’ March 2023 claim was subject to two program integrity holds, which were
implemented on June 23, 2023, and June 26, 2023, respectively.

12. As to the first hold, the Division sent Abrams a fact-finding request on June 23, 2023.
The Division received the requested information from Mr. Abrams that same day, and the
hold was released on June 27, 2023.

13. As to the second hold, the Division sent Mr. Abrams a fact-finding request on June 26,
2023, but it did not receive the requested information from Mr. Abrams within seven
days, so the hold was not released.

14. Mr. Abrams began reporting employment income again in Q3 of 2023, ending that
unemployment claim. Mr. Abrams continued to report income throughout the entirety of
Q4 of 2024, until January 31, 2025.

15. On March 30, 2023, Mr. Abrams tried to withdraw his 2023 claim for benefits, but his
request was denied by a deputy of the Division. Mr. Abrams received a copy of the
deputy’s decision, which included a notice of the right to appeal the deputy’s decision to a
hearing officer within 20 days the decision was mailed.

16. Mr. Abrams exercised his right to appeal the deputy’s decision to the hearing officer. The
hearing officer affirmed the deputy’s decision. Mr. Abrams received a copy of the hearing
officer’s decision, which included a notice of the right to appeal the decision to a panel of
the Industrial Claims Appeals Office (“ICAO”) within 20 days the decision as mailed.

17. Abrams exercised his right to appeal the hearing officer’s decision to the ICAO. A panel
of the ICAO affirmed the hearing officer’s decision. Mr. Abrams received a copy of the
ICAO panel’s decision, which included a notice of the right to appeal the panel’s decision
to the Colorado Court of Appeals within 20 days the decision was mailed.
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18. Mr. Abrams did not exercise his right to appeal the ICAO panel’s decision to the
Colorado Court of Appeals.

19. Mr. Abrams received payments on his 2023 unemployment claim from March 18,2023
through June 17,2023. Once the program integrity was adjudicated as eligible, the
claimant received his payment from June 17,2023 through June 24,2023 paid on March
21st, 2025. On the new claim, payments were paid from February 8, 2025 through April
12,2025. The claimant request benefits for the week ending April 19,2025 but has not
received payment since it was just requested Today.
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Mr. Abrams’ 2025 Claim for Benefits

20. The Division received a second claim for benefits from Mr. Abrams effective February 2,
2025.

21. At the time the Division received Mr. Abrams’ 2025 claim, it had still not received the
information requested from the program integrity factfinding sent on June 26, 2023, and
the hold was still in place.

22. On March 15, 2025, the Division received the requested information from Mr. Abrams.
The program integrity hold was cleared on March 17, 2025.

23. The Division adjudicated Mr. Abrams’ separation on March 18, 2025.

24. On March 20, 2025, Mr. Abrams began receiving benefits from his 2025 claim.

25. As of the date of this writing, Mr. Abrams has been paid unemployment benefits via
direct deposit from February 8, 2025, through the week ending April 12, 2025. Benefit
week ending April 19, 2025 has not released payment since he just requested payment
today, Monday the 21st.

26. If a claim for benefits is denied, a copy of the decision is sent to the claimant. The
decision provides notice of the right to appeal the decision to a hearing officer within 20
days.

27. As of this writing, Mr. Abrams has not appealed any decision about his 2025 claim for
benefits to a hearing officer.

I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true
and correct to the best of my knowledge.

Executed this 21st day of April 2025.

___________________________________

Guadalupe Diaz
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EXHIBIT D D
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DECLARATION OF DAVID KIMBALL

I, David Kimball, being over age 18 and of sound mind do state as follows:

1. I am employed by the Colorado Department of Labor and Employment (“CDLE”) in the
Division of Unemployment Insurance (“the Division”). I have worked for the Division
for the past 19 years. My current title is Manager, Customer Support Center Labor and
Employment Specialist V.

2. Claimants are able to contact the Division regarding their unemployment claim by phone,
U.S. mail, online through the MyUI+ portal, or in-person.

3. In my role, I am responsible for managing the Division’s call center, including 9
supervisors and 102 agents. The call center is the initial entry point for many
unemployment claimants. Call center agents can assist with claim filing, adjudication of
non-separation decisions, and answering questions and giving guidance for claimants in
the unemployment system.

4. Call center agents are available to answer phone calls Monday through Friday, from 8
a.m. to 4 p.m.

5. The Division’s phone system has a total of 150 phone lines, which are divided up into 12
active queues. Each active queue can accommodate 10 people on hold, allowing up to
120 people to be on hold at a time.

6. Once the system reaches 120 people on hold, the system puts additional callers into a
separate queue, which can hold up to 150 people at a time. Once this queue reaches 150
people, new callers will receive a notification that the queue is full and be given an option
to speak with a virtual assistant. The virtual assistant can answer basic questions about
claims, including how to file an unemployment claim and how to appeal a decision of the
Division.

7. At present, the Division does not employ enough staff to be able to bring average hold
times under 30 minutes. Based on the number of calls coming in on a daily basis, I
estimate the Division would need an additional 60 full-time agents to bring average hold
times under 30 minutes.

8. Claimants have multiple methods to contact the Division online. The primary method is
MyUI+, an online portal where claimants can file an unemployment claim, manage an
existing claim, request benefit payments, review tax information, update contact
information, respond to requests for information, upload documents, verify their identify,
and view correspondence from the Division.

9. A claimant who simply needs to provide documents or forms may upload the documents
through the Division’s online “document submission form.”
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10. Claimants can also complete a Claimant Feedback Form located at
https://co.tfaforms.net/f/uifeedback. Categories for feedback include:

a. Do you disagree with your decision?

b. Were you unable to contact an agent or schedule a call back?

c. Are you contacting us because your claim has not been processed and it has been
over 12 weeks?

d. The agent I spoke to was rude or unprofessional.

11. When the Division receives a Claimant Feedback Form indicating the claimant was
unable to contact an agent or schedule a call back, the request is reviewed by a subject-
matter expert who may reach out to a supervisor if needed.

12. At present, the Division does not employ enough staff to be able to support a call back
option. Based on the number of calls coming in on a daily basis, I estimate the Division
would need an additional 60 full-time agents to support a call back option.

13. Kiosks are available at the Division for claimants who do not have computer access, and
staff are available to assist with questions regarding online systems.

14. Claimants can also drop off documents in a secure dropbox located in the Division’s
lobby and available from Monday to Friday from 8 a.m. to 4 p.m.

15. Claimants can also receive in-person assistance by appointment. A claimant may schedule
an in-person appointment by completing a form online. Claimants must confirm that they
have reviewed the self-help options available before making an in-person appointment.

16. Appointments are available for claimants who have limited access to a computer, limited
tech skills, or individual assistive needs; for claimants who are unable to use online tools
to verify their identity; and for claimants who need to provide evidence of economic
hardship, such as an eviction notice or utility bill.

17. As of the date of this writing, Joshua Abrams has an active unemployment claim and is
receiving benefits. Mr. Abrams previously made a claim for unemployment benefits in
March 2023.

18. I have reviewed Mr. Abrams’ claim file, including call center activity.

19. Mr. Abrams has been in contact with the Division by phone several times in 2023 and
2025:

a. On March 3, 2023, Mr. Abrams spoke with a call center agent and was given basic
claim information.
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b. On March 15, 2023, Mr. Abrams spoke with a call center agent and was given
information on verifying his identity.

c. Mr. Abrams also spoke with call center agents twice on April 11, 2023, and once
on July 5, 2023.

20. Mr. Abrams also spoke with call center agents twice on March 14, 2025, for a total of
approximately 90 minutes. The two calls on that date concerned a program integrity hold
that was placed on Mr. Abrams’ claim. That hold was lifted on March 17, 2025, after Mr.
Abrams provided documentation sufficient to lift the hold.

I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true
and correct to the best of my knowledge.

Executed this _21st_ day of April 2025.

David E. Kimball

David Kimball
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EXHIBIT E
E
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EXHIBIT F

F
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UI-PDF
Claim Program Week Payment Payment Weekly Additions Gross Deductions Net Overpayment Payment Payment Total Weekly Earnings Other Pension Authorized Total Calculated Child Colorado Out-of-state Total Federal Tax State Tax Total Weekly
ID End ID Date Benefit Amount Payment Status Method Earnings Benefit Deductions Deductible Amount Additional Authorized Support Overpayment Overpayment Taxable Withholding Withholding Deductions Payment
Date Amount Amount Reported Amount Income Payments Amount Offset Offset Amount Amount
202301 Standard 6/24/ 45362407 3/20/ $139.00 $0.00 $75.00 $11.00 $64.00 N Processed Direct $0.00 Military Self Part Time $0.00 $75.00 $0.00 $75.00 $0.00 $0.00 $0.00 $75.00 $8.00 $3.00 $11.00 $64.00
UI 2023 2025 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 6/24/ 40593636 6/28/ $139.00 $0.00 $0.00 $0.00 $0.00 N Week Direct $0.00 Military Self Part Time $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
UI 2023 2023 Denied Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 6/17/ 40548051 6/21/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 6/10/ 40505584 6/14/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 6/3/ 40465453 6/7/2023 $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 5/27/ 40422589 5/31/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 5/20/ 40381004 5/24/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 5/13/ 40332330 5/17/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 5/6/ 40299020 5/10/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 4/29/ 40255220 5/3/2023 $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 4/22/ 40206859 4/26/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 4/15/ 40157122 4/19/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 4/8/ 40107950 4/12/ $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 4/1/ 40073788 4/6/2023 $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 3/25/ 40069020 4/6/2023 $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 3/25/ 40034045 4/3/2023 $139.00 $0.00 $0.00 $0.00 $0.00 N Week Direct $0.00 Military Self Part Time $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
UI 2023 Denied Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 3/18/ 40069020 4/6/2023 $139.00 $0.00 $139.00 $20.00 $119.00 N Processed Direct $0.00 Military Self Part Time $0.00 $139.00 $0.00 $139.00 $0.00 $0.00 $0.00 $139.00 $14.00 $6.00 $20.00 $119.00
UI 2023 Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 3/18/ 40034045 4/3/2023 $139.00 $0.00 $0.00 $0.00 $0.00 N Week Direct $0.00 Military Self Part Time $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
UI 2023 Denied Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
202301 Standard 3/11/ 40034045 4/3/2023 $139.00 $0.00 $0.00 $0.00 $0.00 N Waiting Direct $0.00 Military Self Part Time $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
UI 2023 Week Deposit Earnings Employment Earnings
Reported: Earnings Reported:
Reported:
Case No. 1:24-cv-03390-RMR Document 33-1 filed 04/28/25 USDC Colorado pg
22 of 24

EXHIBIT G

G
Case No. 1:24-cv-03390-RMR Document 33-1 filed 04/28/25 USDC Colorado pg
23 of 24
1-Calls Hitting VA Ivy IVR

Report Criteria:
Start: Jan 1, 2023 12:00:00 AM Mountain Daylight Time
End: Apr 14, 2025 11:58:00 PM Mountain Daylight Time
Campaign Type: Inbound

Advanced filters:
1 ANI equals 6099689360
Advanced filter conditions: 1

TIMESTAMP ANI CALL TIME AGENT FIRST DNIS
NAME
Fri, 3 Mar 2023 10:56:15 6099689360 00:03:34 - 3033189000
Fri, 3 Mar 2023 11:01:17 6099689360 00:03:06 - 3033189000
Fri, 3 Mar 2023 11:05:14 6099689360 00:02:45 - 3033189000
Mon, 6 Mar 2023 10:58:22 6099689360 00:03:04 - 8003885515
Mon, 6 Mar 2023 11:03:10 6099689360 00:00:11 - 8883907936
Mon, 6 Mar 2023 13:41:18 6099689360 00:03:30 - 3033189000
Sun, 12 Mar 2023 15:27:26 6099689360 00:00:03 - 8885502800
Sun, 12 Mar 2023 15:27:28 6099689360 00:01:23 - 8885502800
Tue, 14 Mar 2023 12:19:00 6099689360 00:01:09 - 8885502800
Sun, 19 Mar 2023 12:41:21 6099689360 00:03:04 - 8003885515
Mon, 20 Mar 2023 11:26:11 6099689360 00:03:52 - 8003885515
Mon, 20 Mar 2023 11:30:05 6099689360 00:04:14 - 8003885515
Mon, 20 Mar 2023 11:34:21 6099689360 00:02:24 - 8003885515
Mon, 20 Mar 2023 11:36:47 6099689360 00:04:39 - 8003885515
Mon, 20 Mar 2023 11:42:56 6099689360 00:03:24 - 3033189035
Mon, 10 Apr 2023 16:28:29 6099689360 00:00:10 - 3033189299
Tue, 11 Apr 2023 10:09:20 6099689360 00:07:33 Daniel 3033189299
Tue, 11 Apr 2023 11:00:57 6099689360 00:11:37 Cliff 3033189299
Tue, 6 Jun 2023 22:04:16 6099689360 00:00:06 - 8003885515
Tue, 20 Jun 2023 09:55:47 6099689360 00:01:00 - 3033189000
Wed, 5 Jul 2023 12:14:47 6099689360 00:08:28 Chiquita 3033189035
Sat, 2 Mar 2024 17:41:51 6099689360 00:02:08 - 8003885515
Thu, 6 Feb 2025 09:17:00 6099689360 00:01:10 - 3038132800
Sun, 9 Feb 2025 18:59:16 6099689360 00:04:33 - 3038132800
Thu, 13 Feb 2025 11:56:18 6099689360 00:00:37 - 3038132800
Fri, 14 Feb 2025 12:23:18 6099689360 00:00:57 - 3038132800
Sun, 16 Feb 2025 12:55:31 6099689360 00:03:50 - 3038132800
Sun, 23 Feb 2025 17:56:47 6099689360 00:03:23 - 3038132800
Sun, 23 Feb 2025 18:19:12 6099689360 00:00:59 - 8003885515
Sun, 23 Feb 2025 18:21:35 6099689360 00:00:18 - 3033189000
Mon, 24 Feb 2025 08:24:46 6099689360 00:01:52 - 3033189000
Mon, 24 Feb 2025 09:02:20 6099689360 00:01:57 - 3033189000
Mon, 24 Feb 2025 10:46:17 6099689360 00:01:53 - 3033189000
Mon, 24 Feb 2025 11:37:04 6099689360 00:01:34 - 3033189000
Mon, 24 Feb 2025 14:24:10 6099689360 00:01:45 - 3033189000
Mon, 24 Feb 2025 15:50:53 6099689360 00:01:59 - 3033189000
Tue, 25 Feb 2025 13:06:54 6099689360 00:02:09 - 3033189000
Tue, 25 Feb 2025 15:29:28 6099689360 00:01:37 - 3033189000
Wed, 26 Feb 2025 09:05:53 6099689360 00:02:48 - 3033189000
Wed, 26 Feb 2025 10:39:50 6099689360 00:01:58 - 3033189000
Tue, 4 Mar 2025 08:12:26 6099689360 00:02:03 - 3033189000
Wed, 5 Mar 2025 14:12:01 6099689360 00:02:05 - 8003885515
Thu, 6 Mar 2025 11:37:07 6099689360 00:02:01 - 8003885515
Thu, 6 Mar 2025 11:39:18 6099689360 00:01:56 - 8003885515

14-Apr-2025 Page 1 of 2
Case No. 1:24-cv-03390-RMR Document 33-1 filed 04/28/25 USDC Colorado pg
24 of 24
1-Calls Hitting VA Ivy IVR

Fri, 7 Mar 2025 12:30:56 6099689360 00:01:51 - 8003885515
Fri, 7 Mar 2025 12:36:11 6099689360 00:01:57 - 8003885515
Mon, 10 Mar 2025 08:57:57 6099689360 00:01:33 - 8003885515
Fri, 14 Mar 2025 09:01:02 6099689360 00:38:19 Sylvia 8003885515
Fri, 14 Mar 2025 10:33:55 6099689360 00:01:33 - 8003885515
Fri, 14 Mar 2025 10:35:31 6099689360 00:02:30 - 8003885515
Fri, 14 Mar 2025 13:10:32 6099689360 00:52:58 Edward 8003885515
Fri, 14 Mar 2025 13:35:07 6099689360 00:52:58 Edward 8003885515
Fri, 14 Mar 2025 13:59:59 6099689360 00:52:58 Edward 8003885515
Tue, 18 Mar 2025 13:48:14 6099689360 00:02:02 - 8003885515
Mon, 7 Apr 2025 10:43:22 6099689360 00:11:18 Leo 3033188441

14-Apr-2025 Page 2 of 2

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SHA-256: 7e7ec1851102f9a3eecfa5b2deadb2a0b67afbbd9d6c3af0decb31778d6b1c0b
Our copy: gov.uscourts.cod.239393.33.1.pdf
Original: PACER (login required)

Declaration Of Jeff Newcomb, Doc. 33-1 — D. Colo., CourtListener docket 239393

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