Declaration of Stephen Hindle — In re Bank of America California Unemployment Benefits Litigation
- Date
- 2025-10-17
Summary
DX 13, filed October 17, 2025 as Document 591-23 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 Stephen Hindle, 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 April 4, 2025 Expert Rebuttal Report, attached to another declaration as DX 13-A. It states the report rests on the declarant's education, research and experience working with call centers, including for large banks, and on materials made available in the action. The caption notes exhibits filed provisionally under seal pursuant to a stipulated protective order.
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Case 3:21-md-02992-GPC-MSB Document 591-23 Filed 10/17/25 PageID.41267
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DX 13
Case 3:21-md-02992-GPC-MSB Document 591-23 Filed 10/17/25 PageID.41268
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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 STEPHEN
HINDLE 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
HINDLE DECL. ISO MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 591-23 Filed 10/17/25 PageID.41269
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1 I, Stephen Hindle, declare and state as follows:
2 1. I am over 18 years of age and am competent to testify in this matter. I make
3 this declaration in support of Defendant Bank of America, N.A. 's (BANA) Motion
4 for Partial Summary Judgment.
5 2. I have been retained by BANA to serve as an expert in this case.
6 3. lf called as a witness at trial, I would testify to each and all of the opinions
7 and statements contained in my April 4, 2025 Expert Rebuttal Report submitted in
8 this matter (Expert Report), a true and correct copy of which is attached to the
9 Declaration of Laura G. Brys as DX 13-A.
10 4. The contents of my Expert Report are based on my personal knowledge,
11 education, training, academic research, and professional industry eA'])erience working
12 with call centers for a variety of institutions including large banks, as well as the
13 information and documents made available to me in this action, as listed in the report
14 itself.
15 I, Stephen Hindle, declare under penalty of perjury that the foregoing is true
16 and correct. Executed on this 10th day of October 2025.
17 p
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STEPHEN HlNDLE
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GOODWIN PROCTER LlJ'
All\Jlf,fMA1 LAW
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HINDLE DECL. ISO MOT. FOR PARTIAL J Case No. 2 l-MD-02992-GPC-MSB
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