Bank of America will suffer “grave and irreparable harm” if Merrill Lynch employees paid $3.6 billion in bonuses just before the firm’s acquisition by the bank are publicly identified, its lawyers said.

BofA filed documents in state court in Manhattan to intervene in a case brought by New York Attorney General Andrew Cuomo to compel former Merrill boss John Thain to testify about the bonus recipients.

The information Cuomo seeks would provide a “road map” revealing which business lines the banks believe to be most valuable and enable competitors to poach the bank’s top talent, BofA argued in the court filing.