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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flmb.uscourts.gov

In re: 

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

Chapter 7

Debtor.

______________________/

CHRISTI LEE STRAUB,

Plaintiff,

vs. Adv. No.: 21-01155-EPK

MISSOURI HIGHER EDUCATION 

LOAN AUTHORITY and THE UNITED 

STATES DEPARTMENT OF 

EDUCATION and THE UNIVERSITY 

OF MINNESOTA

Defendants,

________________________/

PLAINTIFF’S INITIAL DISCLOSURES PURSUANT TO FED. R. CIV. P. 26(a)(1)

Plaintiff, CHRISTI LEE STRAUB (“Ms. Straub” or “Plaintiff”), pursuant to Rule 26(a)(1) 

of the Federal Rules of Civil Procedure, made applicable to this proceeding by Rule 7026 of the 

Federal Rules of Bankruptcy Procedure, and this Court’s Order Setting Filing and Disclosure 

Requirements for Pretrial and Trial (DE #21), hereby submit its Initial Disclosures:

I. Name and, if known, the address and telephone number of each individual likely to 

have discoverable information that Plaintiff may use to support its claims or defenses, unless 

solely for impeachments, identifying the subjects of the information:

A. Christi Lee Straub

6106 Birch Drive

Fort Pierce, FL 34982

Subject of information: Historical information and circumstances surrounding the 

agreement(s) between the parties, information supporting Plaintiff’s allegations, and 

records of relevant communications between the parties.

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B. Christopher Bolander or Corporate Representative of U.S. Dept. of ED

50 Beale Street

San Francisco, CA 94105

Subject of information: Historical information and circumstances surrounding the 

agreement(s) between the parties, and records of relevant communications between 

the parties.

C. All witnesses listed by the Defendant.

D. Plaintiff reserves the right to amend and/or supplement this list after the discovery 

process has been completed.

I. Description by category and location of all documents, electronically stored 

information, and tangible things that the parties have in their possession, custody, or control 

and may use to support their claims or defenses, unless solely for impeachment:

A. Plaintiff’s bankruptcy schedules. 

B. All documents disclosed by the Defendant or obtained during discovery.

C. All documents produced in response to third party subpoenas duces tecum.

D. All documents listed by the Defendant its Initial Disclosure.

E. Plaintiff reserves the right to amend and/or supplement this list after the discovery 

process has been completed.

I. Computation of damages:

A. No damages, Plaintiff seeks to discharge otherwise non-dischargeable debts under

the undue hardship provision of § 523(a)(8) of the Bankruptcy Code.

VAN HORN LAW GROUP, P.A.

500 NE 4th St., Suite 200

Fort Lauderdale, Florida 33301

(954) 765-3166

(954) 756-7103 (facsimile)

Chad@cvhlawgroup.com

By: /s/ Chad T. Van Horn, Esq.

Chad T. Van Horn, Esq.

Fla Bar #64500

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing has been furnished this 23rd day of

March, 2022, by the Court’s ECF Filing system and/or via U.S. mail to all parties registered to 

receive filings in the instant case.

VAN HORN LAW GROUP, P.A.

500 NE 4th St., Suite 200

Fort Lauderdale, Florida 33301

(954) 765-3166

(954) 756-7103 (facsimile)

Chad@cvhlawgroup.com

By: /s/ Chad T. Van Horn, Esq.

Chad T. Van Horn, Esq.

Fla Bar #64500

Case 21-01155-MAM Doc 25 Filed 03/23/22 Page 3 of 3