Declaration of Russell Cronan — In re Bank of America California Unemployment Benefits Litigation (S.D. Cal.)
- Date
- 2025-10-17
Summary
The declaration of Russell Cronan in support of Defendant Bank of America, N.A.'s motion for partial summary judgment 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, filed October 17, 2025 as Document 591-15. The three-page filing opens with an exhibit slip sheet, followed by a caption page from Goodwin Procter LLP as attorneys for the bank that lists a date of April 17, 2026 before Judge Gonzalo P. Curiel and states that exhibits are filed provisionally under seal. The declaration states that the declarant was retained by the bank as an expert and would testify to the opinions in the declarant's March 4, 2025 Expert Report and April 4, 2025 Expert Rebuttal Report. It is executed on the 13th day of October 2025.
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Full text
Case 3:21-md-02992-GPC-MSB Document 591-15 Filed 10/17/25 PageID.40997
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DX 10
Case 3:21-md-02992-GPC-MSB Document 591-15 Filed 10/17/25 PageID.40998
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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 RUSSELL
CRONAN 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
CRONAN DECL. ISO MOT. FOR PARTIAL SJ CASE NO. 21-MD-02992-GPC-MSB
Case 3:21-md-02992-GPC-MSB Document 591-15 Filed 10/17/25 PageID.40999
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1 I, Russell Cronan, 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. If called as a witness at trial , I would testify to each and all of the opinions
7 and statements contained in my March 4, 2025 Expert Report and my April 4, 2025
8 Expert Rebuttal Report submitted in this matter (Expert Reports), true and correct
9 copies of which are attached to the Declaration of Laura G. Brys as DX 10-A and 10-
10 B respectively.
11 4. The contents of my Expert Reports are based on my personal knowledge,
12 education, training, academic research, and professional industry experience in
13 banking regulatory enforcement and compliance, including compliance with
14 Regulation E, as well as the information and documents made available to me in this
15 action, as listed in the report itself.
16 I, Russell Cronan, declare under penalty of perjury that the foregoing is true
17 and correct. Executed on this 13th day of October 2025 .
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R USSELL CRO AN
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GOODWIN PROCTER LLP
ATTORNE"SAT LAW
1
C RO AN D EC L. ISO MOT. FOR P ARTIAL SJ Case No. 21-MD-029929-GPC-MSB
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- gov.uscourts.casd.709615.591.15.pdf
- Size
- 550,451 bytes
- SHA-256
- b40fcda6da3b234538ca1bb028cd02e1e406852e01aca0d86175d57ad9193fcf
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