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 U.S. DEPARTMENT OF EDUCATION’S INITIAL DISCLOSURES

Defendant, the U.S. Department of Education (“U.S. Dept. of ED”), hereby submits, in 

accordance with this Court’s Order Setting Filing and Disclosure Requirements for Pretrial and 

Trial [ECF No. 21], the following initial disclosures, pursuant to Federal Rule of Civil Procedure 

26(a)(1), as incorporated by Federal Rule of Bankruptcy Procedure 7026:

Federal Rule of Civil Procedure 26(a)(1)(A)(i): The name, and, if known, the address and 

telephone number of each individual likely to have discoverable information—along with the 

subjects of that information—that the disclosing party may use to supports its claims or defenses, 

unless the use would be solely for impeachment.

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Response:

1. Christopher Bolander or Corporate Representative of U.S. Dept. of ED (via 

deposition)1

50 Beale St.

San Francisco, CA 94105

Subject of Information: A representative from U.S. Dept of ED likely has 

discoverable information regarding the Debtor’s loan history and payment plan 

options available to the Debtor.

2. Christi Lee Straub

6106 Birch Drive

Fort Pierce, FL 34982

Subject of Information: Christi Lee Straub likely has discoverable information 

regarding the student loan liabilities referenced in the complaint, or any amended 

versions thereof, and all alleged facts supporting the Debtor’s allegations of undue 

hardship.

3. All witnesses named by Plaintiff.

4. Any person named in a deposition or referenced in any document produced in this 

proceeding, or whose name is learned during the course of discovery.

5. All persons necessary to authenticate documents.

6. Any rebuttal and impeachment witnesses.

Federal Rule of Civil Procedure 26(a)(1)(A)(ii): A copy—or a description by category and 

location—of all documents, electronically stored information, and tangible things that the 

disclosing party has in its possession, custody, or control and may use to support its claims or 

defenses, unless the use would be solely for impeachment.

Response:

1. All documents evidencing Plaintiff’s student loan obligations now owed to U.S. 

Dept. of ED.

2. All documents evidencing the amount of Plaintiff’s outstanding student loan 

obligations that remain due and owing to U.S. Dept. of ED. 

1 To the extent necessary, U.S. Dept. of ED intends on using the deposition of Christopher Bolander or another 

representative of U.S. Dept. of ED at trial in lieu of live testimony because the assigned Department of Education loan 

analysts work in San Francisco, California.

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3. Plaintiff’s Bankruptcy Schedules of Assets and Liabilities and Statement of 

Financial Affairs.

4. Any documents or papers filed by Plaintiff in this adversary proceeding or in 

Plaintiff’s main bankruptcy case.

5. Any document or papers filed by Plaintiff in any other adversary proceeding.

6. Plaintiff’s United States Income Tax Returns for the five (5) years prior to the 

Petition Date.

7. All documents relating to the allegations in Plaintiff’s Complaint, or any amended 

versions thereof, and U.S. Dept. of ED’s Answer thereto.

8. All documents produced by Plaintiff in this adversary proceeding, including any 

documents that Plaintiff may provide and/or produce in response to U.S. Dept. of 

ED’s discovery requests or discovery requests from any other party.

9. Plaintiff’s Answers to U.S. Dept. of ED’s First Set of Interrogatories and any other 

answers Plaintiff have or may provide to any other party in this adversary 

proceeding.

10. All documents produced by any party during discovery.

11. All documents produced by any third party in this adversary proceeding.

12. All deposition exhibits, if any.

13. Federal Regulations relating to the William D. Ford Program, 34 C.F.R. §685.100 

et. seq., and the Income Based Repayment, 34 C.F.R. §§ 682.215 and 685.221.

14. Department of Health and Human Services Poverty Guidelines for 2021.

15. Any and all rebuttal exhibits.

16. Any and all impeachment exhibits

Federal Rule of Civil Procedure 26(a)(1)(A)(iii): A computation of each category of damages 

claimed by the disclosing party—who must also make available for inspection and copying as 

under Rule 34 the documents or other evidentiary material, unless privileged or protected from 

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disclosure, on which each computation is based, including materials bearing on the nature and 

extent of injuries suffered.

Response:

No damages are sought in this action, as the adversary proceeding instituted by Plaintiff seeks to 

discharge Plaintiff’s otherwise non-dischargeable student loan obligations as an undue hardship.

Federal Rule of Civil Procedure 26(a)(1)(A)(iv): For inspection and copying as under Rule 34, 

any insurance agreement under which an insurance business may be liable to satisfy all or part of 

a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the 

judgment.

Response:

Federal Rule of Civil Procedure 26(a)(1)(A)(iv) is not applicable in this adversary proceeding.

Reservation of Right to Amend or Supplement Initial Disclosures

U.S. Dept. of ED reserves the right to supplement and/or amend these disclosures as appropriate 

and necessary.

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

By: s/Raychelle Tasher

RAYCHELLE TASHER

Assistant United States Attorney

Florida Bar No. 109291

Raychelle.Tasher@usdoj.gov

99 N.E. 4th Street, Suite 300

Miami, Florida 33132

Telephone: (786) 439-3185

Fax: (305) 530-7139

Counsel for Defendant, 

United States Dept. of Education 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 22, 2022, 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.

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

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

/s/Raychelle A. Tasher

RAYCHELLE A. TASHER

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