UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

IN RE: 

CHRISTI LEE STRAUB, Case No.: 21-13230-EPK

CHAPTER 7

Debtor.

______________________________/

CHRISTI LEE STRAUB, Adv. No. 21-01155-EPK

Plaintiff,

vs. 

MISSOURI HIGH EDUCATION

LOAN AUTHORITYAND THE

UNITED STATES DEPARTMENT 

OF EDUCATION AND THE UNIVERSITY

OF MINNESOTA,

Defendants.

_______________________________/

DEFENDANT UNITED STATES DEPARTMENT OF EDUCATION’S 

ANSWER TO PLAINTIFF’S COMPLAINT

The United States of America, on behalf of the United States Department of Education 

(“Education”), hereby files its answer to the Plaintiff’s Complaint (D.E. 1) and states as follows:

1. Education admits paragraph 1.

2. Education admits paragraph 2. 

3. Education without sufficient information or knowledge to admit or deny Paragraph 

3 and therefore denies the same.

4. Education without sufficient information or knowledge to admit or deny Paragraph 

4 and therefore denies the same.

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5. Education without sufficient information or knowledge to admit or deny Paragraph 

5 and therefore denies the same.

6. Education admits paragraph 6.

7. Education admits paragraph 7.

8. Education without sufficient information or knowledge to admit or deny Paragraph 

8 and therefore denies the same.

9. Education without sufficient information or knowledge to admit or deny Paragraph 

9 and therefore denies the same.

10. Education without sufficient information or knowledge to admit or deny Paragraph 

10 and therefore denies the same.

11. Education without sufficient information or knowledge to admit or deny Paragraph 

11 and therefore denies the same.

12. Education without sufficient information or knowledge to admit or deny Paragraph 

12 and therefore denies the same.

13. Education without sufficient information or knowledge to admit or deny Paragraph 

13 and therefore denies the same.

14. Education without sufficient information or knowledge to admit or deny Paragraph 

14 and therefore denies the same.

15. Education without sufficient information or knowledge to admit or deny Paragraph 

15 and therefore denies the same.

16. The allegations in paragraph 16 constitute legal conclusions to which no responsive 

pleading is required. To the extent that the Court deems a responsive pleading is necessary, 

Education denies paragraph 16.

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17. Education without sufficient information or knowledge to admit or deny Paragraph 

17 and therefore denies the same.

18. Education without sufficient information or knowledge to admit or deny Paragraph 

18 and therefore denies the same.

19. Education without sufficient information or knowledge to admit or deny Paragraph 

19 and therefore denies the same.

20. Education without sufficient information or knowledge to admit or deny Paragraph 

20 and therefore denies the same.

21. Education without sufficient information or knowledge to admit or deny Paragraph 

21 and therefore denies the same.

22. Education without sufficient information or knowledge to admit or deny Paragraph 

22 and therefore denies the same.

23. Education without sufficient information or knowledge to admit or deny Paragraph 

23 and therefore denies the same.

24. Education without sufficient information or knowledge to admit or deny Paragraph 

24 and therefore denies the same.

25. Education without sufficient information or knowledge to admit or deny Paragraph 

25 and therefore denies the same.

26. Education without sufficient information or knowledge to admit or deny Paragraph 

26 and therefore denies the same.

27. Education without sufficient information or knowledge to admit or deny Paragraph 

27 and therefore denies the same.

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28. Education without sufficient information or knowledge to admit or deny Paragraph 

28 and therefore denies the same.

29. Education without sufficient information or knowledge to admit or deny Paragraph 

29 and therefore denies the same.

30. Education without sufficient information or knowledge to admit or deny Paragraph 

30 and therefore denies the same.

31. Education without sufficient information or knowledge to admit or deny Paragraph 

31 and therefore denies the same.

32. Education without sufficient information or knowledge to admit or deny Paragraph 

32 and therefore denies the same.

33. Education without sufficient information or knowledge to admit or deny Paragraph 

33 and therefore denies the same.

34. Education without sufficient information or knowledge to admit or deny Paragraph 

34 and therefore denies the same.

35. Education without sufficient information or knowledge to admit or deny Paragraph 

35 and therefore denies the same.

36. Education without sufficient information or knowledge to admit or deny Paragraph 

36 and therefore denies the same.

37. Education without sufficient information or knowledge to admit or deny Paragraph 

37 and therefore denies the same.

38. Education without sufficient information or knowledge to admit or deny Paragraph 

38 and therefore denies the same.

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39. Education without sufficient information or knowledge to admit or deny Paragraph 

39 and therefore denies the same.

40. Education without sufficient information or knowledge to admit or deny Paragraph 

40 and therefore denies the same.

41. Education without sufficient information or knowledge to admit or deny Paragraph 

41 and therefore denies the same.

42. Education without sufficient information or knowledge to admit or deny Paragraph 

42 and therefore denies the same.

43. Education without sufficient information or knowledge to admit or deny Paragraph 

43 and therefore denies the same.

44. Education without sufficient information or knowledge to admit or deny Paragraph 

44 and therefore denies the same.

45. Education without sufficient information or knowledge to admit or deny Paragraph 

45 and therefore denies the same. 

46. Education without sufficient information or knowledge to admit or deny Paragraph 

46 and therefore denies the same.

47. Education without sufficient information or knowledge to admit or deny Paragraph 

47 and therefore denies the same.

48. Education without sufficient information or knowledge to admit or deny Paragraph 

48 and therefore denies the same.

49. Education without sufficient information or knowledge to admit or deny Paragraph 

49 and therefore denies the same.

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50. Education without sufficient information or knowledge to admit or deny Paragraph 

50 and therefore denies the same.

51. Education without sufficient information or knowledge to admit or deny Paragraph 

51 and therefore denies the same.

52. Education without sufficient information or knowledge to admit or deny Paragraph 

52 and therefore denies the same.

53. Education without sufficient information or knowledge to admit or deny Paragraph 

53 and therefore denies the same.

54. Education without sufficient information or knowledge to admit or deny Paragraph 

54 and therefore denies the same.

55. Education without sufficient information or knowledge to admit or deny Paragraph 

55 and therefore denies the same.

56. Education admits paragraph 56.

57. Education admits paragraph 57.

58. Education admits paragraph 58.

59. Education without sufficient information or knowledge to admit or deny Paragraph 

59 and therefore denies the same.

60. Education without sufficient information or knowledge to admit or deny Paragraph 

60 and therefore denies the same.

61. The allegation in paragraph 61 constitutes a legal conclusion to which no 

responsive pleading is required. To the extent that the Court deems a responsive pleading is 

necessary, Education denies paragraph 61.

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62. The allegation in paragraph 62 constitutes a legal conclusion to which no 

responsive pleading is required. To the extent that the Court deems a responsive pleading is 

necessary, Education denies paragraph 62.

63. Education without sufficient information or knowledge to admit or deny Paragraph 

63 and therefore denies the same.

64. Education without sufficient information or knowledge to admit or deny Paragraph 

64 and therefore denies the same.

65. Education without sufficient information or knowledge to admit or deny Paragraph 

65 and therefore denies the same.

66. The allegations in paragraph 66 constitute legal conclusions to which no responsive 

pleading is required. To the extent that the Court deems a responsive pleading is necessary, 

Education denies paragraph 66.

67. The allegation in paragraph 67 constitutes a legal conclusion to which no 

responsive pleading is required. To the extent that the Court deems a responsive pleading is 

necessary, Education denies paragraph 67.

The remaining unnumbered section of the complaint represents the Plaintiff’s prayer for 

relief to which no responsive pleading is required. To the extent that the Court deems a responsive 

pleading is required, Education not only denies the allegations but also denies that Plaintiff is 

entitled to any of the relief requested.

WHEREFORE, having fully answered the Complaint, Education respectfully requests 

that this Court:

1. Enter judgment in favor of Education;

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2. Declare that the student loans owed by the Plaintiff to Education are 

nondischargeable pursuant to 11 U.S.C. § 523(a)(8); and

3. Grant any other and further relief as the Court deems just and proper.

Respectfully submitted,

JUAN ANTONIO GONZALEZ

ACTING UNITED STATES ATTORNEY

BY: s/RAYCHELLE TASHER 

RAYCHELLE TASHER

Assistant United States Attorney

Florida Bar No. 109291

E-mail: Raychelle.Tasher@usdoj.gov

United States Attorney’s Office

99 N.E. 4th Street, Third Floor

Miami, Florida 33132

Telephone: (305) 439-3185

Facsimile: (305) 530-7139

Counsel for Defendant, 

United States Dept. of Education

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on September 23, 2021, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day by transmission of Notices of Electronic Filing generated by CM/ECF to 

those parties registered to receive electronic notices of filing in this case or via U.S. mail as listed 

in the below Service List.

s/RAYCHELLE TASHER 

RAYCHELLE TASHER

Service List

21-01155-EPK Notice will be electronically mailed to: 

Raychelle A Tasher on behalf of Defendant U.S. Department of Education

Raychelle.Tasher@usdoj.gov, Milton.Pacheco@usdoj.gov;Shannon.Patterson@usdoj.gov

Chad T Van Horn on behalf of Plaintiff Christi Lee Straub

Chad@cvhlawgroup.com, 

chad@ecf.inforuptcy.com,g2320@notify.cincompass.com,chapter7@cvhlawgroup.com,chapter13@cvhla

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wgroup.com,chapter11@cvhlawgroup.com;vanhorn.chadb104447@notify.bestcase.com

Case 21-01155-EPK Doc 14 Filed 09/23/21 Page 9 of 9