BANA EDD Cloninger Hoyle Decl. to Reply ISO MTS Draft

Summary

The Declaration of Lindsay E. Hoyle in Support of Defendant Bank of America, N.A.'s Reply in Support of Its Motion to Exclude the Purported Expert Opinions of Jane Cloninger, filed February 20, 2026 as Document 672-1 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 is Counsel at Goodwin Procter LLP and counsel of record for BANA. It states that attached as HX 50 is a true and correct copy of part of the official transcript of BANA's deposition of Jane Cloninger, taken on June 11, 2025. The header states that the exhibit is filed provisionally under seal pursuant to the Stipulated Protective Order.

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HOYLE DECL. ISO CLONINGER REPLY
CASE NO. 3:21-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 LINDSAY E.
HOYLE IN SUPPORT OF
DEFENDANT BANK OF AMERICA,
N.A’S REPLY IN SUPPORT OF ITS
MOTION TO EXCLUDE THE
PURPORTED EXPERT OPINIONS OF
JANE CLONINGER
Ctrm:
12A – 12th Floor
Judge:
Hon. Gonzalo P. Curiel
EXHIBIT FILED PROVISIONALLY UNDER SEAL
PURSUANT TO STIPULATED PROTECTIVE
ORDER

Case 3:21-md-02992-GPC-MSB     Document 672-1     Filed 02/20/26     PageID.58757
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HOYLE DECL. ISO CLONINGER REPLY
CASE NO. 3:21-MD-02992-GPC-MSB

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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
I, Lindsay E. Hoyle, state and declare as follows:
1.
I am Counsel at Goodwin Procter LLP, and counsel of record for
Defendant Bank of America, N.A. (BANA) in the above-captioned lawsuit.
2.
I have personal knowledge of the facts set forth in this declaration, and
if called upon to do so, I could and would competently testify thereto.
3.
I make this declaration in support of BANA’s Reply in Support of its
Motion to Exclude Purported Expert Opinions of Jane Cloninger.
4.
Attached hereto as HX 50 is a true and correct copy of excerpts of the
official transcript of BANA’s deposition of Jane Cloninger, taken on June 11, 2025.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 20, 2026 in New York, New York.

/s/Lindsay E. Hoyle

LINDSAY E. HOYLE

Case 3:21-md-02992-GPC-MSB     Document 672-1     Filed 02/20/26     PageID.58758
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