IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

EDUARDO GARCIA and JULIA GARCIA,

Plaintiffs,

v.

WELLS FARGO BANK, N.A., 

Defendant.

Case No. 1:20-cv-02402

Hon. Rebecca R. Pallmeyer

ORAL ARGUMENT REQUESTED

DECLARATION OF SHAWN R. OBI IN SUPPORT OF DEFENDANT’S 

MOTION FOR PROTECTIVE ORDER STRIKING PLAINTIFFS’ RULE 30(b)(6) 

DEPOSITION NOTICE

I, Shawn R. Obi, hereby declare as follows:

1. I am an attorney licensed to practice in the State of California, have been admitted 

pro hac vice in the State of Illinois, and am a partner with Winston & Strawn LLP, counsel for 

Defendant Wells Fargo Bank, N.A. (“Defendant” or “Wells Fargo”) in the above-captioned 

matter. 

2. On February 9, Wells Fargo agreed that Plaintiffs may use deposition transcripts 

from Hernandez v. Wells Fargo (No. 3:18-cv-7354-WHA, N.D. Cal.), as well as documents and 

exhibits produced by Wells Fargo in that case. In exchange for that agreement, Plaintiffs agreed 

that they would not seek to re-depose the same witnesses or seek testimony on any topic that was 

covered by prior Rule 30(b)(6) testimony in Hernandez. 

3. On April 21, 2022, Plaintiffs served seven deposition notices on Wells Fargo, 

including a Rule 30(b)(6) notice. Exhibit 1 is a true and correct copy of Plaintiffs’ 30(b)(6) 

notice, served on April 21, 2022.

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4. On April 26, 2022, the parties met and conferred over a number of discovery 

issues, including the 30(b)(6) topics.

5. On April 29, 2022, the parties met and conferred for a second time.

6. On May 1, 2022, Plaintiffs served an amended notice that included 23 topics. 

Exhibit 2 is a true and correct copy of Plaintiffs’ amended notice, served on May 1, 2022.

7. On May 3, 2022, the parties met and conferred for a third time on the 30(b)(6) 

topics.

8. On May 5, 2022, Plaintiffs served a further amended Notice that included 31 

topics and 24 sub-topics. Exhibit 3 is a true and correct copy of Plaintiffs’ further amended 

notice, served on May 5, 2022.

9. On April 26 and May 3, 2022, Plaintiffs agreed during a meet and confer that 

Wells Fargo is not required to educate a witness on Topic Nos. 1-4 of the notice of 30(b)(6) 

deposition.

10. Exhibit 4 is a true and correct copy of various consent decrees from 2011, 2013, 

2015, 2018, and 2021 highlighted by Plaintiffs and provided to Wells Fargo on May 3, 2022.

11. Exhibit 5 is a true and correct copy of the notice of 30(b)(6) deposition from 

Hernandez.

12. Exhibit 6 is a true and correct copy of excerpts from the deposition transcript of 

Wells Fargo executive Carmen Bell in Hernandez. 

13. Exhibit 7 is a true and correct copy of the forbearance agreement offered to 

Plaintiffs in 2009 and denial letter.

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I hereby declare under the penalty of perjury that the foregoing statements made by me 

are true and correct.

Dated: May 12, 2022 /s/ Shawn R. Obi

Shawn R. Obi

Case: 1:20-cv-02402 Document #: 86-1 Filed: 05/12/22 Page 3 of 4 PageID #:885
Certificate of Service

The undersigned, an attorney, hereby certifies that on the 12th day of May, 2022, the 

foregoing Declaration of Shawn R. Obi in Support of Defendant’s Motion For Protective Order 

Striking Plaintiffs’ Rule 30(B)(6) Deposition Notice was filed electronically with the Clerk of the 

Court for the United States District Court for the Northern District of Illinois, and was served by 

operation of that Court’s electronic filing system on all parties of record. 

Dated: May 12, 2022 /s/ Shawn R. Obi

Shawn R. Obi

Case: 1:20-cv-02402 Document #: 86-1 Filed: 05/12/22 Page 4 of 4 PageID #:886