Declaration of Carl Pry — In re Bank of America (S.D. Cal.)

Summary

DX 9, the Declaration of Carl Pry in Support of Defendant Bank of America, N.A.'s Motion for Partial Summary Judgment, filed October 17, 2025 as Document 591-13 in In re: Bank of America California Unemployment Benefits Litigation, Case No. 21-MD-02992-GPC-MSB, U.S. District Court for the Southern District of California, San Diego Division. The declaration states that the declarant has been retained by BANA to serve as an expert in the case. It states that, if called as a witness at trial, the declarant would testify to the opinions and statements in an April 4, 2025 Expert Report attached to the Declaration of Laura G. Brys as DX 9-A. The declaration is dated October 10, 2025 and gives the basis of the report as personal knowledge, education, training, academic research and professional industry experience.

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Full text

DX 9
Case 3:21-md-02992-GPC-MSB     Document 591-13     Filed 10/17/25     PageID.40949
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PRY DECL. ISO MOT. FOR PARTIAL SJ
CASE NO. 21-MD-02992-GPC-MSB
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
JAMES W. MCGARRY (pro hac vice)
JMcGarry@goodwinlaw.com
GOODWIN PROCTER LLP
100 Northern Avenue
Boston, MA 02210
Tel. +1 617 570 1000
Fax: +1 617 523 1231
SABRINA M. ROSE-SMITH (pro hac vice)
SRoseSmith@goodwinlaw.com
MATTHEW L. RIFFEE (pro hac vice)
MRiffee@goodwinlaw.com
GOODWIN PROCTER LLP
1900 N Street, NW
Washington, DC 20036
Tel.: +1 202 346 4000
Fax: +1 202 346 4444
Attorneys for Defendant
BANK OF AMERICA, N.A.
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF CALIFORNIA
SAN DIEGO DIVISION
IN RE: BANK OF AMERICA
CALIFORNIA UNEMPLOYMENT
BENEFITS LITIGATION
Case No. 21-MD-02992-GPC-MSB
DECLARATION OF CARL PRY IN
SUPPORT OF DEFENDANT
BANK OF AMERICA, N.A.’S
MOTION FOR PARTIAL
SUMMARY JUDGMENT
Date:
April 17, 2026
Time:
1:30 p.m.
Ctrm:
12A – 12th Floor
Judge:
Hon. Gonzalo P. Curiel
EXHIBITS FILED PROVISIONALLY UNDER
SEAL PURSUANT TO STIPULATED
PROTECTIVE ORDER
Case 3:21-md-02992-GPC-MSB     Document 591-13     Filed 10/17/25     PageID.40950
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PRY DECL. ISO MOT. FOR PARTIAL SJ

Case No. 21-MD-029929-GPC-MSB
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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
I, Carl Pry, declare and state as follows:
1. I am over 18 years of age and am competent to testify in this matter. I make
this declaration in support of Defendant Bank of America, N.A.’s (BANA) Motion
for Partial Summary Judgment.
2. I have been retained by BANA to serve as an expert in this case.
3. If called as a witness at trial, I would testify to each and all of the opinions
and statements contained in my April 4, 2025 Expert Report submitted in this matter
(Expert Report), a true and correct copy of which is attached to the Declaration of
Laura G. Brys as DX 9-A.
4. The contents of my Expert Report are based on my personal knowledge,
education, training, academic research, and professional industry experience in the
regulatory compliance and banking industry, as well as the information and
documents made available to me in this action, as listed in the report itself.
I, Carl Pry, declare under penalty of perjury that the foregoing is true and
correct. Executed on this 10th day of October 2025.

CARL PRY

Case 3:21-md-02992-GPC-MSB     Document 591-13     Filed 10/17/25     PageID.40951
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gov.uscourts.casd.709615.591.13.pdf

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