Declaration of Teresa A. Pesce — In re Bank of America California Unemployment Benefits Litigation
Summary
The Declaration of Teresa A. Pesce in support of Defendant Bank of America, N.A.'s Motion for Partial Summary Judgment, filed October 17, 2025 as Document 591-18 in In re: Bank of America California Unemployment Benefits Litigation, Case No. 21-MD-02992-GPC-MSB, in the U.S. District Court for the Southern District of California. The declarant states having been retained by Goodwin Procter LLP, counsel for BANA, to serve as an expert in the case. The declaration states that, if called as a witness at trial, the declarant would testify to the opinions in the March 4, 2025 and April 4, 2025 Expert Reports, attached to another declaration as Exhibits 11-A and 11-B. The caption lists a hearing before Judge Gonzalo P. Curiel. The three-page document was executed in October 2025.
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Case 3:21-md-02992-GPC-MSB Document 591-18 Filed 10/17/25 PageID.41095
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Case 3:21-md-02992-GPC-MSB Document 591-18 Filed 10/17/25 PageID.41096
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1 JAMES W. MCGARRY (pro hac vice)
JMcGarry@goodwinlaw.com
2 GOODWIN PROCTER LLP
100 Northern Avenue
3 Boston, MA 02210
Tel. +1 617 570 1000
4 Fax: +1 617 523 1231
5 SABRINA M. ROSE-SMITH (pro hac vice)
SRoseSmith@goodwinlaw.com
6 MATTHEW L. RIFFEE (pro hac vice)
MRiffee@goodwinlaw.com
7 GOODWIN PROCTER LLP
1900 N Street, NW
8 Washington, DC 20036
Tel.: +1 202 346 4000
9 Fax: +1 202 346 4444
10 Attorneys for Defendant
BANK OF AMERICA, N.A.
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UNITED STATES DISTRICT COURT
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FOR THE SOUTHERN DISTRICT OF CALIFORNIA
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SAN DIEGO DIVISION
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16 IN RE: BANK OF AMERICA Case No. 21-MD-02992-GPC-MSB
CALIFORNIA UNEMPLOYMENT
17 BENEFITS LITIGATION DECLARATION OF TERESA A.
PESCE IN SUPPORT OF
18 DEFENDANT BANK OF
AMERICA, N.A.’S MOTION FOR
19 PARTIAL SUMMARY JUDGMENT
20 Date: April 17, 2026
21 Time: 1:30 p.m.
Ctrm: 12A – 12th Floor
22 Judge: Hon. Gonzalo P. Curiel
23 EXHIBITS FILED PROVISIONALLY UNDER
SEAL PURSUANT TO STIPULATED
24 PROTECTIVE ORDER
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
PESCE DEC. ISO MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 591-18 Filed 10/17/25 PageID.41097
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1 I, Teresa A. Pesce, declare and state as follows:
2 1. I am over 18 years of age and am competent to testify in this matter. I
3 make this declaration in support of Defendant Bank of America, N.A.’s (BANA)
4 Motion for Partial Summary Judgment.
5 2. I have been retained by Goodwin Procter LLP, counsel for BANA to serve
6 as an expert in this case.
7 3. If called as a witness at trial, I would testify to each and all of the opinions
8 and statements contained in my March 4, 2025 Expert Report and my April 4, 2025
9 Expert Report submitted in this matter (Expert Reports), true and correct copies of
10 which are attached to the Declaration of Laura G. Brys as Exhibits 11-A and 11-B
11 respectively.
12 4. The contents of my Expert Reports are based on my personal knowledge,
13 education, training, research, and professional industry experience in the field of
14 financial-crimes, regulatory enforcement, and compliance, as well as the information
15 and documents made available to me in this action, as referenced in the Expert
16 Reports.
17 I, Teresa A. Pesce, declare under penalty of perjury that the foregoing is true
18 and correct. Executed on this 13 day of October 2025.
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TERESA A. PESCE
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
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PESCE DEC. ISO BANA’S PARTIAL MSJ Case No. 21-MD-029929-GPC-MSB
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