Declaration of Pamela Joseph — In re Bank of America California Unemployment Benefits Litigation
- Date
- 2025-10-17
Summary
DX 12, filed October 17, 2025 as Document 591-19 in In re: Bank of America California Unemployment Benefits Litigation, Case No. 3:21-md-02992-GPC-MSB, in the U.S. District Court for the Southern District of California. It is the declaration of Pamela Joseph, an expert retained by Bank of America, N.A., in support of the bank's Motion for Partial Summary Judgment, set for hearing April 17, 2026 before Judge Gonzalo P. Curiel. The declarant states that, if called as a witness, the declarant would testify to the opinions in the March 4, 2025 and April 4, 2025 Expert Reports, attached to another declaration as Exhibits 12-A and 12-B. It states the reports rest on the declarant's education, research and experience in the electronic payments industry and on materials made available in the action. The caption notes exhibits filed provisionally under seal under a stipulated protective order.
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Case 3:21-md-02992-GPC-MSB Document 591-19 Filed 10/17/25 PageID.41098
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DX 12
Case 3:21-md-02992-GPC-MSB Document 591-19 Filed 10/17/25 PageID.41099
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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 PAMELA
JOSEPH IN SUPPORT OF
18 DEFENDANT BANK OF
AMERICA, N.A.’S MOTION FOR
19 PARTIAL SUMMARY
20 JUDGMENT
21 Date: April 17, 2026
Time: 1:30 p.m.
22 Ctrm: 12A – 12th Floor
Judge: Hon. Gonzalo P. Curiel
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EXHIBITS FILED PROVISIONALLY UNDER
24 SEAL PURSUANT TO STIPULATED
PROTECTIVE ORDER
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
JOSEPH DECL. ISO MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 591-19 Filed 10/17/25 PageID.41100
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I, Pamela Joseph, declare and state as follows:
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1. I am over 18 years of age and am competent to testify in this matter. I
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make this declaration in support of Bank of America, N.A. 's (BANA) Motion for
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Partial Summary Judgment.
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2. I have been retained by BANA to serve as an expert in this case.
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3. If called as a witness at trial, I would testify to each and all of the
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opinions and statements contained in my March 4, 2025 Expert Report and my
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April 4, 2025 Expert Report submitted in this matter (Expert Reports), true and
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correct copies of which are attached to the Declaration of Laura G. Brys as Exhibits
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12-A and 12-B respectively.
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4 .. The contents of my Expert Reports are based on my personal knowledge,
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education, training, academic research, and professional industry experience in the
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electronic payments industry, as well as the information and documents made
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available to me in this action, as listed in the report itself.
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I, Pamela Joseph, declare under penalty of perjury that the foregoing is true
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and correct. Executed on this 11 1 " day of October 2025.
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
-2-
JOSEPH DECL. ISO OF BANA'S PARTIAL MSJ CASE NO. 21-MD-029929-GPC-MSR
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