Exhibit 4

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

EDUARDO GARCIA and JULIA GARCIA,

 Plaintiffs,

 vs.

WELLS FARGO BANK, N.A., 

 Defendant.

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Case No. 1:20-cv-02402

Honorable Rebecca R. Pallmeyer

PLAINTIFF’S RULE 26(a) THIRD SUPPLEMENTAL INITIAL DISCLOSURES

Plaintiffs Eduardo Garcia and Julia Garcia, by and through counsel, hereby provides the 

following third supplemental disclosures pursuant to Rule 26(e) of the Federal Rules of Civil 

Procedure. Plaintiffs continue their investigation and reserve the right to supplement these 

disclosures in accordance with Rule 26(e).

1. State the names and, if known, the addresses and telephone numbers of all persons 

who you believe are likely to have discoverable information relevant to any party’s claims or 

defenses and provide a fair description of the nature of the information each person is believed to 

possess.

ANSWER: 

● Eduardo Garcia

Eduardo Garcia is one of the Plaintiffs in this action. Mr. Garcia may be 

contacted through counsel. Mr. Garcia has information as detailed in the 

Complaint filed herein.

● Julia Garcia

Julia Garcia is one of the Plaintiffs in this action. Mrs. Garcia may be contacted 

through counsel. Mrs. Garcia has information as detailed in the Complaint filed 

herein.

● Byron Garcia

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Byron Garcia is the son of Eduardo and Julia Garcia and is expected to testify 

as to how Wells Fargo’s conduct affected his family and his parents. Byron 

Garcia is still represented by Plaintiffs’ counsel and may be reached by 

contacting Plaintiffs’ counsel. 

● Miriahm Garcia

Miriahm Garcia is the daughter of Eduardo and Julia Garcia and is expected to 

testify as to how Wells Fargo’s conduct affected her family and her parents. 

Miriahm Garcia continues to be represented by Plaintiffs’ counsel and may be 

reached by contacting Plaintiffs’ counsel. 

● Domingo Garcia

Domingo Garcia is Eduardo’s brother and has information concerning the 

issues Eduardo and Julia were going through with Wells Fargo and their 

attempts to keep their house.

● Kathy Kapsa

Kathy Kapsa was, at all times relevant to this case, a licensed realtor. Ms. Kapsa 

worked with the Garcias when they originally purchased the property located 

at 407 Beach Avenue, LaGrange Park, IL in 2002. In 2009, Ms. Kapsa listed 

the Garcias’ house for sale. Ms. Kapsa has information regarding the 

improvements the Garcias made to the property, the issues the Garcias had with 

the Loan, and the Garcias’ reasons for listing the house for sale.

● Susan Vega

Susan Vega is a friend and was Julia’s co-worker from 2004-2012. Ms. Vega 

has information concerning the issues Eduardo and Julia were going through 

with Wells Fargo and their attempts to keep their house.

● Martha Polo Koehler

Martha Polo Koehler has been a spiritual, academic and personal counselor, and 

Julia’s supervisor. Ms. Koehler has information concerning the issues Eduardo 

and Julia were going through with Wells Fargo and their attempts to keep their 

house.

● Elena Briseño

Elena Briseño is a friend and was Julia’s co-worker from 2005-2012. Ms. 

Briseño has information concerning the issues Eduardo and Julia were going 

through with Wells Fargo and their attempts to keep their house.

● Rosa Garcia

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Rosa Garcia is Julia’s sister and has information concerning the issues Eduardo 

and Julia were going through with Wells Fargo and their attempts to keep their 

house.

● Anita Pillai, M.D.

Anita Pillai, M.D., is the Garcias’ Primary Care Medical Provider with 

Elmhurst. She has information concerning the stress and its detrimental affects 

on Julia’s fibromyalgia, and medical history of Eduardo, Byron and Miriahm.

• Wells Fargo Bank, N.A.

Wells Fargo Bank, N.A. (“Wells Fargo”) is the Defendant in this case and may 

be contacted through counsel. Wells Fargo has information as detailed in the 

Complaint herein.

• Wells Fargo & Company

Wells Fargo Bank, N.A. is the primary subsidiary of Wells Fargo & Company 

(“WFC”). WFC may be contacted through Defendant’s counsel. WFC has 

information as detailed in the Complaint herein.

• Robert Ferguson

Mr. Ferguson, a Loan Administration Manager for Wells Fargo Home 

Mortgage, was a 30(b)(6) witness for Wells Fargo in Hernandez (deposed on 

July 10, 2019) and also submitted a Declaration dated December 10, 2019, in 

support of Wells Fargo’s opposition to Plaintiffs’ renewed motion for class 

certification. Wells Fargo has identified Mr. Ferguson as a person who may 

have information responsive to the interrogatories.

• Carmen Bell

Ms. Bell, a Senior Vice President for Wells Fargo Home Mortgage, was a 

30(b)(6) witness for Wells Fargo in Hernandez (deposed on August 2, 2019) 

and also submitted a Declaration dated December 31, 2018, in support of Wells 

Fargo’s response to order to show cause stating, “I have read the complaint filed 

by Plaintiff Alicia Hernandez and, relevant here, I was primarily responsible 

for determining impacted customers and the remediation plan for the issues 

described in the complaint.” Hernandez, et al. vs. Wells Fargo (No. 3:18-cv7354-WHA, N.D. Cal.), Dkt. 24-1. According to Wells Fargo, during the 

relevant time period, Ms. Bell was Head, Wells Fargo Home Mortgage 

Customer Contact and Default Decisions. Wells Fargo has identified Ms. Bell 

as a person who may have information responsive to the interrogatories. 

• Diane Young

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Ms. Young has been employed by Wells Fargo for more than 20 years and 

during the relevant time period, Ms. Young a Project Manager. In 2014 to 2015, 

Ms. Young was the project manager for a technology update, “Corporate 

Advance and State Attorney Fee Matrix Research.” Ms. Young was deposed in 

Hernandez on July 19, 2019. Wells Fargo has identified Ms. Young as a person 

who may have information responsive to the interrogatories

• Tom Wayne

Mr. Wayne, at all times relevant, was a Vice President/Lending Officer of Wells 

Fargo Home Mortgage Default Servicing - Default Decisioning. Mr. Wayne has 

been an employee of Wells Fargo for more than 11 years and was actively 

involved in the Corporate Advance and State Attorney Fee Matrix Research 

Project. Mr. Wayne has information as detailed in the Complaint herein. 

• Beena Menon

Ms. Menon was employed by Wells Fargo for 10 years. She was Head of 

Default Decisions at Wells Fargo from 2013 to 2018. According to her LinkedIn 

profile, Ms. Menon “assumed leadership of the Default Decision operation, 

leading 4,000+ team members in supporting home preservation efforts for all 

servicing portfolios, including government-sponsored entities, companyowned, and private investors.” Ms. Menon was Executive Vice President, 

Enterprise Services from 2018 until she left Wells Fargo in July 2021. Ms. 

Menon was deposed in Hernandez on August 21, 2019. According to Wells 

Fargo, Ms. Menon was Head of Enterprise Utility Services during the relevant 

time period. Wells Fargo has identified Ms. Menon as a person who may have 

information responsive to the interrogatories.

• Susan Crawford

During the relevant time period, Ms. Crawford was employed by Wells Fargo 

as Operational Risk Consultant. Ms. Crawford was one of the employees who 

warned Wells Fargo that incorrect loan modification denials would result if 

Wells Fargo did not fix the error and yet, Wells Fargo continued to use the tool 

because it did not want to spend the money to fix it. Ms. Crawford was deposed 

in Hernandez on November 14, 2019. Wells Fargo has identified Ms. Crawford 

as a person who may have information responsive to the interrogatories.

• Daniel N. Pfeil

Mr. Pfeil was, at all times relevant to this matter, employed by Wells Fargo as 

a Credit Portfolio Consultant, and was actively involved in the Corporate 

Advance and State Attorney Fee Matrix Research Project. Mr. Pfeil was 

deposed in Hernandez on November 14, 2019. Wells Fargo has identified Mr. 

Pfeil as a person who may have information responsive to the interrogatories.

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• Kara Reimers

Ms. Reimers has been employed by Wells Fargo for over 18 years. She was a 

Lending Officer at Wells Fargo from 2003 to February 2020, Operational Risk 

Consultant, Vice President, from August 2019 to February 2020, and 

Operational Risk Officer from February 2020 to present. Ms. Reimers was 

deposed in Hernandez on November 20, 2019. Wells Fargo has identified Ms. 

Reimers as a person who may have information responsive to the 

interrogatories.

• Michael Bates

Mr. Bates was employed as a HAMP Specialist with Wells Fargo. Mr. Bates 

communicated with the Garcias regarding their loan modification application. 

Wells Fargo has identified Mr. Bates as an employee who may have worked on 

the Garcias’ application and may have information responsive to the 

interrogatories

• Erika Diaz

Ms. Diaz has been employed by Wells Fargo for over 13 years. She currently 

lists her position with Wells Fargo as Wholesale Relationship Associate II 

(09/2021 to present). Wells Fargo has identified Ms. Diaz as a person who may 

have information responsive to the interrogatories.

• Wendy Spaziani

Ms. Spaziani was employed by Wells Fargo during the Garcias’ application for 

a loan modification. Mr. Garcia faxed loan modification documents to Ms. 

Spaziani. Wells Fargo has identified Ms. Spaziani as an employee who may 

have worked on the Garcias’ application and may have information responsive 

to the interrogatories.

• Danny Mccarl

Mr. Mccarl was employed as a Loan Verification Analyst with Wells Fargo 

during the Garcias’ application for a loan modification. Wells Fargo has 

identified Mr. Mccarl as an employee who may have worked on the Garcias’ 

application and may have information responsive to the interrogatories.

• Casey Goodrich

Ms. Goodrich was employed as a Loan Verification Analyst with Wells Fargo 

during the Garcias’ application for a loan modification. Wells Fargo has 

identified Ms. Goodrich as an employee who may have worked on the Garcias’ 

application and may have information responsive to the interrogatories.

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• M. Keith Hallman

Mr. Hallman was employed as a HAMP Analyst with Wells Fargo. In 10/2010 

and 02/2011, Mr. Hallman signed certifications pertaining to the Garcias’ loan 

modification application stating: “The borrower has been evaluated for HAMP 

and was determined to be ineligible for the program.” Wells Fargo has 

identified Mr. Hallman as an employee who may have worked on the Garcias’ 

application and may have information responsive to the interrogatories.

• Drew Standridge

Mr. Standridge was employed as a HAMP Analyst with Wells Fargo. In 

12/2010, Mr. Standridge signed a certification pertaining to the Garcias’ loan 

modification application stating: “The borrower has been evaluated for HAMP 

and was determined to be ineligible for the program.” Wells Fargo has 

identified Mr. Standridge as an employee who may have worked on the Garcias’ 

application and may have information responsive to the interrogatories.

• Ben Windust

Mr. Windust was a Senior Vice President for Wells Fargo Home Mortgage. Mr. 

Windust authored a letter to borrowers regarding HAMP. Upon information and 

belief, Mr. Windust was Sponsor for the HAMP - Decision Making GSE Tool 

Rewrite (Release: 2009). Wells Fargo has identified Mr. Windust as an 

employee who may have worked on the Garcias’ application and may have 

information responsive to the interrogatories.

• Robert Seneney

Wells Fargo has identified Mr. Seneney as an employee who may have worked 

on the Garcias’ application and may have information responsive to the 

interrogatories.

• Brent Potter

Mr. Potter was employed as a Senior Vice President, SPOC, for Wells Fargo 

Home Mortgage and was directly involved with Wells Fargo’s Remediation 

Plan. Wells Fargo has identified Mr. Potter as a person who may have 

information responsive to the interrogatories.

• Stirling Carpenter

Mr. Carpenter was employed as a Loss Mit Supervisor for Wells Fargo. Mr. 

Carpenter, along with Capricia Wizzard-Murray, Loss Mit Specialist, reviewed 

the Garcias’ loan modification application and documents and on 02/02/2011, 

recommended removal from Loss Mit. Wells Fargo has identified Mr. 

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Carpenter as an employee who may have worked on the Garcias’ application 

and may have information responsive to the interrogatories.

• Annette Baez

Ms. Baez’s name appears on WF_GARCIA_00001463, Snapshot (HAMP-Tier 

1-Std) dated 08/24/2010, the date that the Garcias’ loan modification 

application was erroneously and wrongly denied. Wells Fargo has identified 

Ms. Baez as an employee who may have worked on the Garcias’ application 

and may have information responsive to the interrogatories.

• Mike Nold

Mr. Nold, at all times relevant, was an employee of Wells Fargo and is currently 

a lending officer with Wells Fargo. Mr. Nold was actively involved in the 

Corporate Advance and State Attorney Fee Matrix Research Project. Mr. Nold 

has information as detailed in the Complaint herein.

• Perry J. Hilzendeger

Mr. Hilzendeger, at all times relevant, was a Senior Vice President of Wells

Fargo, Default Services and Real Estate Servicing. Mr. Hilzendeger was 

actively involved in the investigation of Wells Fargo’s servicing issues and has 

information concerning Wells Fargo’s HPA Tool errors and claims as detailed 

in the Complaint herein.

● Unknown Representatives of Wells Fargo Bank, N.A. and/or Wells Fargo & 

Company

Unknown Representatives of Wells Fargo Bank, N.A. and/or Wells Fargo & 

Company may have information regarding Wells Fargo’s policies and 

procedures pertaining to consumer’s eligibility for HAMP and other loss 

mitigation programs and foreclosure; Wells Fargo’s mortgage modification 

software, errors in Wells Fargo’s mortgage modification software;

examinations and audits conducted by the Office of Comptroller of the 

Currency (“OCC”) and the Federal Reserve, and consent orders; Wells Fargo’s

policies and procedures pertaining to its investigation of the errors resulting in 

Wells Fargo’s improper denial of several hundred loan modification 

applications; and information as detailed in the Complaint herein.

● Unknown third parties

Unknown third parties associated with Wells Fargo’s loss mitigation

processing, mortgage modification software, determination of consumer’s 

eligibility for a loan modification, approvals and denials of loan modification 

applications, foreclosures, and may have knowledge and information regarding 

Wells Fargo’s policies and procedures pertaining to same.

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2. Description by category of all documents, data compilations and tangible things 

that are in Plaintiffs’ possession, custody or control, that may be used to support their claims:

ANSWER: The Garcias have in their possession the following documents which have been 

produced, to date:

Bates 

Number Date Document Description

1 11/20/2008 Wells Fargo loan modification denial (Exhibit A to Complaint)

2 - 3 11/12/2010 Wells Fargo loan modification denial (Exhibit A to Complaint)

4 - 5 12/01/2010 Wells Fargo loan modification denial (Exhibit A to Complaint)

6 02/07/2011 Wells Fargo loan modification denial (Exhibit A to Complaint)

7 - 10 07/26/2019 Wells Fargo letter re: Wells Fargo’s error; check payable to Mr. 

Garcia in amount of $14,500 (Exhibit B to Complaint)

11 - 12 11/18/2019

Wells Fargo letter re: Wells Fargo’s error and additional check 

payable to Mr. Garcia in the amount of $10,000 (Exhibit C to 

Complaint)

13 11/25/2019 Wells Fargo letter to Mr. Garcia re: 07/26/2019 check in amount 

of $14,500 not cashed (Exhibit D to Complaint)

14 04/18/2020

Zillow Estimate of subject property located 407 Beach Ave., 

LaGrange Park, IL 60526, as of April 18, 2020 (Exhibit E to 

Complaint)

15 - 27

01/08/2009

to

03/29/2011

Foreclosure Docket - Cook County Case No. 2009-CH-00855 

Deutsche Bank vs. Garcias, et al.

28 - 60 01/08/2009 Summons and Complaint Deutsche Bank v. Garcias, et al., Cook 

County Case No. 2009-CH-00855

61 - 109 05/26/2011 Garcia Chapter 7 Voluntary Petition (ND IL BK Case No. 11-

22208)

110 - 113 09/07/2011 Discharge Order entered in Garcia’s Chapter 7

114 - 287 06/30/2018 Wells Fargo & Company Form 10-Q

288 - 466 09/30/2018 Wells Fargo & Company Form 10-Q

467 - 634 09/30/2019 Wells Fargo & Company Form 10-Q

635 - 921 2018 Wells Fargo & Company 2018 Annual Report

922 - 1186 2019 Wells Fargo & Company 2019 Annual Report

1187 - 1190

05/26/2011

to

09/07/2011

Chapter 7 Docket 

(ND Illinois U.S. Bankruptcy Court 11-22208)

Filed: 05/26/2011

Discharged: 09/07/2011

1191 - 1281 04/20/2018

Wells Fargo Form 8-K filed with the SEC, re:

In the Matter of: Wells Fargo Bank, N.A., United States of 

America, Bureau of Consumer Financial Protection, 

Administrative Proceeding 2018-BCFP-0001, Consent Order

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Bates 

Number Date Document Description

In the Matter of Wells Fargo Bank, N.A., United States of 

America Department of the Treasury, Office of the Comptroller 

of the Currency, AA-EC-2018-15, Consent Order, #2018-025 

In the Matter of Wells Fargo Bank, N.A., United States of 

America Department of the Treasury, Office of the Comptroller 

of the Currency, AA-EC-2018-15, Stipulation and Consent to 

the Issuance of a Consent Order

1282 - 1309 09/09/2021

In the Matter of Wells Fargo Bank, N.A., United States of 

America Department of the Treasury, Office of the Comptroller 

of the Currency, Consent Order (Cease and Desist Order) #2021-

035, AA-ENF-2021-29; and 

Consent Order (Civil Money Penalty) #2021-036, AA-ENF2021-30

1310 - 1322 01/28/2010 Supplemental Directive 10-01 Home Affordable Modification 

Program

1323 - 1421 Various Julia’s Paystubs (2007-2011); Byron’s 12/17/2010 Paystub

1422 - 1585 Various

2003, 2007, 2008, 2009, 2010 Tax Returns - Eduardo and Julia 

Garcia

2011-2012 FAFSA with 2010 Tax Return - Byron Garcia

1586 - 1608 03/21/2011 Credit Report - Eduardo Garcia

1609 - 1683 Various Emails between Julia Garcia and CredAbility

1684 - 1709 Various Communications with ASC (Wells Fargo) re: Loan Modification 

Application

1710 - 1730 10/2009

Smothers Realty Group brochure - Listing of the house for sale 

with estimates of expenses for materials and labor for the 

renovation of the property; photos of property

1731 - 1735 02/15/2011 Julia’s Work Evaluation for 01/2010 to 12/2010

Alivio Medical Center (Date of Hire: 09/08/2003)

1736 04/25/2011 Letter to property owner for Brookfield rental

1737 - 1742 01/13/2010 Eduardo’s Application for Custodial position

1743 - 1784 11/16/2010 Asset Acceptance v. Julia Escamilla, Cook County Case No. 

2010-M1-204569

1785 - 1787 03/13/2009 Household Finance v. Julia Escamilla, Cook County Case No. 

2009-M1-121723 (Docket)

1788 - 1899 Various Complete 2010, 2011, 2012 Federal & State Tax Returns -

Eduardo and Julia Garcia

1900 - 1925 2013 2013 Federal & State Tax Returns - Miriahm Garcia

1926 - 2002 2011

2013 2011, 2013 Federal & State Tax Returns - Byron Garcia

2003 03/05/2009 Email from NACA to Julia Garcia 

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Bates 

Number Date Document Description

2004 - 2118 Various

2012 Julia Garcia W-2

2013 - 2015, 2018 - 2019 Federal & State Tax Returns -

Eduardo and Julia Garcia

2119 - 2131 Seminario Biblico Hispano Records re: Julia Escamilla (Garcia) 

produced by Martha Polo Koehler

2132 - 2244 March 2020

The Real Wells Fargo: Board & Management Failures, 

Consumer Abuses, and Ineffective Regulatory Oversight -

Report Prepared by the Majority Staff of the Committee on 

Financial Services, U.S. House of Representatives

BYRON E. GARCIA AND MIRIAHM GARCIA SCHOOL RECORDS

1 - 41 Byron E. Garcia’s school records 

1 - 210 Miriahm Garcia’s school records

MEDICAL RECORDS

1 - 292 Byron E. Garcia’s medical records 

1 - 853 Eduardo Garcia’s medical records

1 - 3322

3323-3691

Julia Garcia’s medical records

1 - 840 Miriahm Garcia’s medical records

In addition to the above documents, Plaintiffs may use documents, deposition 

transcripts and exhibits produced by Wells Fargo in the Hernandez class action.

3. Provide a computation of each category of damages claimed by you, and a 

description of the documents or other evidentiary material on which it is based, including materials 

bearing on the nature and extent of the injuries suffered. You may produce the documents or other 

evidentiary materials with your response instead of describing them.

ANSWER: 

● Actual damages including emotional distress damages. This category of 

damages is considered unliquidated and normally does not require Plaintiffs to 

list a specific amount. However, Garcias’ Counsel is putting Wells Fargo on 

notice they intend to request the jury in this case award at least $20,000,000 in 

compensatory damages in this case. 

● While punitive damages are also considered unliquidated and usually do not 

require disclosure of the amount to be sought for the same reason as general 

compensatory damages, the Garcias’ counsel is putting Wells Fargo on notice 

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they intend to seek an award of at least $100,000,000 in punitive damages in 

this case. That number is a minimum and is subject to sharp upward revision as 

discovery continues. 

Discovery has already revealed Wells Fargo internal documents showing Wells 

Fargo identified the problem that led to the loss of the Garcias’ home in this 

case as early as 2013. Wells Fargo could have corrected the problem for 

approximately $62,000. Wells Fargo could have identified the consumers who 

had been needlessly harmed by this problem in 2013. This would have 

identified the Garcias, and their needless harm could have been remediated as 

early as 2013. 

Instead, Wells Fargo closed the issue and ignored the problem for several more 

years. This compounded the magnitude of needless harm the Garcias suffered 

due to Wells Fargo’s callous disregard for the consumers Wells Fargo 

needlessly harmed. Wells Fargo’s actions also more than doubled the length of 

time the Garcias suffered needless harm. Wells Fargo’s documents also lead to 

the ready inference that Wells Fargo was prepared to pay almost a billion dollars 

to resolve this issue if consumers were willing to litigate. 

Instead, Wells Fargo has escaped any financial punishment for this wrongdoing. 

Wells Fargo has resolved its class litigation as well as its regulatory exposure 

on the cheap. This case represents the last opportunity for a jury to punish Wells 

Fargo for this wrongdoing. 

● Legal fees for preparing/filing/prosecuting this action: Plaintiff has incurred 

approximately $270,670 in legal fees to date in the prosecution of this matter. 

The amount of these damages will continue to grow as this matter continues.

● Costs for Instant Action: Plaintiff has incurred $639.69 in costs to date related 

to the instant action including but not limited to the filing of the Complaint.

4. Specifically identify and describe any insurance or other agreement under which an 

insurance business or other person or entity may be liable to satisfy all or part of a possible 

judgment in the action or to indemnify or reimburse a party for payments made by the party to 

satisfy the judgment. You may produce a copy of the agreement with your response instead of 

describing it.

ANSWER: Not applicable to Plaintiff.

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Dated: March 9, 2022 Respectfully submitted,

/s/ Nick Wooten

Nicholas H. Wooten - Lead Trial Counsel

NICK WOOTEN, LLC

5125 Burnt Pine Drive

Conway, Arkansas 72034

(833) 937-6389

nick@nickwooten.com

/s/ Rusty A. Payton

Rusty A. Payton,

PAYTON LEGAL GROUP

20 North Clark Street, Suite 3300

Chicago, Illinois 60602

(773) 682-5210

info@payton.legal

/s/ Salvador J. Lopez

Salvador J. Lopez

ROBSON & LOPEZ, LLC

180 W. Washington Street, Suite 700

Chicago, Illinois 60602

312-523-2166

lopez@robsonlopez.com

Counsel for Plaintiff

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CERTIFICATE OF SERVICE

I certify that on March 9, 2022, a copy of the foregoing Plaintiffs’ Rule 26(a) Third Supplemental 

Initial Disclosures was served via electronic means on:

Scott P. Glauberman

Christopher Parker

WINSTON & STRAWN LLP

35 West Wacker Drive

Chicago, Illinois 60601

sglauber@winston.com

cparker@winston.com

Angela A. Smedley

WINSTON & STRAWN LLP

200 Park Avenue

New York, NY 10166-4193

Asmedley@winston.com

Shawn R. Obi

WINSTON & STRAWN LLP

333 South Grand Avenue

Los Angeles, CA 90071

Sobi@winston.com

Counsel for Defendant

By: /s/ Nick Wooten

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