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2 reason I did not focus on this in my report is that many 11:51AM
Date
2026-02-20
Full text
HX 52
Case 3:21-md-02992-GPC-MSB Document 678-3 Filed 02/20/26 PageID.58895
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
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SAN DIEGO DIVISION
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Civil Action No. 21-MD-02992-GPC-MSB
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IN RE: BANK OF AMERICA CALIFORNIA
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UNEMPLOYMENT BENEFITS LITIGATION
____________________________________________________________
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VIDEO DEPOSITION OF CHLOE NOEL EAST, Ph.D.
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May 15, 2025
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APPEARANCES:
ON BEHALF OF THE PLAINTIFFS:
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CAROLINE HUNSICKER, ESQ.
CONNIE K. CHAN, ESQ. (via remote)
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Altshuler Berzon LLP
177 Post Street, Suite 300
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San Francisco, California 94108
Phone: 415-421-7151
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Email: chunsicker@altshulerberzon.com
Email: cchan@altber.com
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and
JOSHUA B. SWIGART, ESQ. (via remote)
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ILANA PLATKIEWICZ, ESQ. (via remote)
Swigart Law Group, APC
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2221 Camino Del Rio S, Suite 308
San Diego, California 92108
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Phone: 866-219-3343
Email: josh@swigartlawgroup.com
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Email: ilana@swigartlawgroup.com
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A. Yes, I believe I did. And I believe the 11:51AM
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reason I did not focus on this in my report is that many 11:51AM
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of the points this paper makes are similar to the points 11:51AM
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in Exhibit 10. 11:51AM
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Q. Which is an article by Ganong. 11:51AM
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A. Yes. 11:51AM
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Q. Okay. After reviewing and refreshing your 11:51AM
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recollection regarding the statements in Exhibit 12, are 11:51AM
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you aware that due to expanded UI and stimulus payments, 11:51AM
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unemployed households with incomes under 1,000 per month 11:51AM
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received replacement rates of over 300 percent? 11:51AM
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A. Yes. 11:51AM
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Q. Okay. Are you aware that survey data 11:52AM
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indicates that U.S. households reported spending only 11:52AM
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approximately 40 percent of their first stimulus check 11:52AM
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with 30 percent saved and another 30 percent used to pay 11:52AM
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down debt? 11:52AM
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MS. HUNSICKER: Objection. Assumes facts. 11:52AM
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A. Can you show me the reference for that? 11:52AM
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Q. (By Ms. Brys) Yes, I can. This will be 11:52AM
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Exhibit 13. 11:52AM
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(Exhibit Number 13 was marked.) 11:52AM
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A. Do you want to mark this? Does it matter? 11:52AM
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Q. Oh. Oh. Oh. I took the wrong -- 11:52AM
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MS. BRYS: There's no sticker. 11:52AM
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CERTIFICATE OF COURT REPORTER
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I, DEANNA BAYSINGER, a Registered Professional
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Reporter and Notary Public within and for the State of
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Colorado, commissioned to administer oaths, do hereby
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certify that previous to the commencement of the
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examination, the witness was duly sworn by me to testify
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the truth in relation to matters in controversy between
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the said parties; that the said deposition was taken in
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stenotype by me at the time and place aforesaid and was
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thereafter reduced to typewritten form by me; and that
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the foregoing is a true and correct transcript of my
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stenotype notes thereof.
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That I am not an attorney nor counsel nor in
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any way connected with any attorney or counsel for any of
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the parties to said action nor otherwise interested in the
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outcome of this action.
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My commission expires: November 8, 2026.
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<%22389,Signature%>
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DEANNA BAYSINGER
Registered Professional Reporter
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Notary Public, State of Colorado
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