BANA EDD - Brys Decl. ISO Class Decert

Summary

A 2-page declaration by Laura G. Brys, a senior attorney at Goodwin Procter LLP for Defendant Bank of America, N.A. (BANA), filed as Document 733-2 in In re Bank of America California Unemployment Benefits Litigation, Case No. 3:21-MD-02992-GPC-MSB, before Judge Gonzalo P. Curiel. It supports BANA's Motion to Decertify the Classes and attaches four exhibits. Exhibits 1 and 2 are the official transcripts of the Motion for Class Certification hearing on January 17, 2025 and the Status Conference hearing on May 28, 2026. Exhibits 3 and 4 are alert memoranda by the United States Department of Labor Office of Inspector General, dated February 22, 2021 and May 28, 2026. Brys executed it on the 8th day of June, 2026.

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Full text

BRYS DECL. ISO DECERT. MOT.
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.

[ADDITIONAL COUNSEL LISTED IN SIGNATURE BLOCK]
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
SAN DIEGO DIVISION
IN RE: BANK OF AMERICA
CALIFORNIA UNEMPLOYMENT
BENEFITS LITIGATION
Case No. 3:21-MD-02992-GPC-MSB
DECLARATION OF LAURA G.
BRYS IN SUPPORT OF BANK OF
AMERICA, N.A.’S MOTION TO
DECERTIFY THE CLASSES
Ctrm:
12A – 12TH Floor
Judge:
Hon. Gonzalo P. Curiel
This Document Relates to All Actions

Case 3:21-md-02992-GPC-MSB     Document 733-2     Filed 06/08/26     PageID.61373
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BRYS DECL. ISO DECERT. MOT.
Case No. 3:21-MD-02992-GPC-MSB

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GOODWIN PROCTER LLP
ATTORNEYS AT LAW
DECLARATION OF LAURA G. BRYS
I, Laura G. Brys, state and declare as follows:
1.
I am an attorney licensed to practice before this Court.
2.
I am a senior attorney at Goodwin Procter LLP, attorneys of record for
Defendant Bank of America, N.A. (BANA) in this action.
3.
I make this declaration in support of BANA’s Motion to Decertify the
Classes. I have personal knowledge of the matters set forth in this Declaration, and
if called upon to do so, I could and would competently testify thereto.
4.
Attached hereto as Exhibit 1 is a true and correct copy of the official
transcript from the Motion for Class Certification hearing on January 17, 2025.
5.
Attached hereto as Exhibit 2 is a true and correct copy of the official
transcript from the Status Conference hearing on May 28, 2026.
6.
Attached hereto as Exhibit 3 is a true and correct copy of an Alert
Memorandum by the United States Department of Labor Office of Inspector General,
dated February 22, 2021.
7.
Attached hereto as Exhibit 4 is a true and correct copy of an Alert
Memorandum by the United States Department of Labor Office of Inspector General,
dated May 28, 2026.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 8th day of June, 2026.

/s/ Laura G. Brys

LAURA G. BRYS

Case 3:21-md-02992-GPC-MSB     Document 733-2     Filed 06/08/26     PageID.61374
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gov.uscourts.casd.709615.733.2.pdf

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gov.uscourts.casd.709615.733.2.pdf

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