Exhibit 2

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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

Judge Rebecca Pallmeyer

Judge Heather K. McShain

JULIA GARCIA’S ANSWERS TO DEFENDANT WELLS FARGO BANK, N.A.’S 

FIRST SET OF INTERROGATORIES

Plaintiff Julia Garcia (“Julia”), by and through her undersigned counsel, hereby submits 

the following answers and objections to the First Set of Interrogatories propounded by Wells Fargo 

Bank, N.A. (“Wells Fargo” or “Defendant”) pursuant to the provisions of Rule 33 of the Federal 

Rules of Civil Procedure. Julia reserves the right to supplement her answers.

INTERROGATORIES

INTERROGATORY NO. 1:

Identify Your employment since January 26, 2006, and please Include the dates of 

employment, the Identity of the employer(s), supervisor(s), and evaluator(s), and the reason(s) 

such employment ended.

ANSWER:

From 01/26/2006 to approximately 9/13/2012, Julia was employed full time at Alivio 

Medical Center. Her supervisor during a short period in 2006 was Carmen Velazquez, after that 

her supervisor became Antonia Rodriguez. Julia resigned from Alivio in September 2012.

Since 2012, Julia has sporadically and infrequently worked as a consultant or independent 

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contractor with several not-for-profit organizations. Some jobs were compensated with stipends, 

others were as a volunteer. The projects that were more formal and more than just a day were with

Family Bridges in 2014, where her supervisor was Maria Buchanan, and with Viva la Salud Studies

(University of Illinois, Rush University, and University of Chicago) on and off throughout the 

years. Dr. Lisa Sanchez-Johnsen was the supervisor of that program. Julia also more recently in 

2020 lead a Covid Education program, that lasted about three months, in partnership with Alivio 

Medical Center under a Department of Human Services grant. Julia’s supervisor for that program 

was Susan Vega.

In 2015 Julia began several different volunteer positions with Seminario Biblico Hispano. 

In or around 2018, Julia became a professor there teaching one class a semester as an independent 

contractor, which she continues doing through today. Julia’s supervisor there is Martha Polo 

Koehler. 

INTERROGATORY NO. 2:

Have You had any Communications or discussions with the employer(s), supervisor(s), 

evaluator(s) and/or co-worker(s) Regarding Your ability to effectively perform Your employment 

duties alleged in paragraph 115(H) of the Complaint? If so, please Identify the employer(s), 

supervisor(s), evaluator(s) and/or co-worker(s) and state the date, location, and substance of Each 

such Communication or discussion.

ANSWER: Julia has spoken about these issues with her primary care doctor – Dr. Anita 

Pilai – over the years. Julia has also spoken with her husband and children about these issues. Julia 

likely also discussed these issues with her co-workers at Alivio at the time – Marco Garduno, Elena 

Briseño, Susan Vega, and Humberto Nava, but given that it has been 10 years, she does not 

remember the exact dates or details of these conversations. Julia likely also spoke about it with her

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supervisor at the time, Antonia Rodriguez. Julia also likely discussed these issues with members 

of her church at the time, one member that she was particularly close to at the time was Carolina 

Duran. But again, since it has been 10 years, Julia doesn’t remember which exact details she would 

have discussed with whom. 

INTERROGATORY NO. 3:

If You claim that you were unemployed at any time since January 26, 2006, please Identify 

the names of Each individual You named as a professional reference while seeking employment. 

ANSWER: Given her ongoing health problems since the relevant time period, Julia has

been unable to seek full time employment since 2012. 

INTERROGATORY NO. 4:

Identify the amount of monthly rent You paid as a tenant at the Brookfield Apartment, as

defined in the Complaint and as alleged in paragraphs 91–94 in the Complaint.

ANSWER: Julia believes that it was approximately $1,300.00 per month, but she does 

not remember the exact amount.

INTERROGATORY NO. 5:

Identify the individual or entity who owned the Brookfield Apartment, as defined in the 

Complaint, at the time you became a tenant there.

ANSWER: Julia believes the owner was identified as 4630 Vernon LLC. Julia believes

Frank Adorno was the owner of this LLC. The information Julia has for him is: 1918 N 76th Court, 

Elmwood Park, IL 60707, (708) 975-1966. However, Julia always communicated with Frank 

Adorno, Jr., who identified himself as the owner’s son and manager of the property.

INTERROGATORY NO. 6:

Identify Each rental property that You applied to, or otherwise considered moving into, 

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after the foreclosure of Your Mortgage.

ANSWER: Julia objects to this Interrogatory on the basis that Wells Fargo foreclosed 

on the Garcias’ property over 10 years ago and it is unreasonable for Wells Fargo to expect her to 

remember “each” rental property the Garcias applied to, or otherwise considered moving into, after 

Wells Fargo wrongly foreclosed on the Garcia’s property and forced them to vacate the property 

on short notice. 

Subject to and without waiving this objection, Julia will testify as to the significant time 

and financial investment made in finding new housing and trying to stay within the same school 

district after they were evicted with a short notice to vacate the home. 

Julia believes the family considered approximately twenty-five apartments. 

INTERROGATORY NO. 7:

Identify Each doctor or healthcare provider, Including Each mental healthcare provider, 

therapist, or counselor, with whom You have consulted since January 26, 2006, and please include 

the dates of treatment, the doctor or healthcare provider’s specialty (if applicable), the reason(s) 

for the consultations, Each diagnosis made, and the treatment(s) prescribed for Each such 

diagnosis.

ANSWER: Julia refers Wells Fargo to her 3,691 pages of medical records and the 

additional medical records that Wells Fargo has received in response to its subpoenas in this case. 

INTERROGATORY NO. 8:

Identify all prescription medications, over-the-counter medications or remedies, and other 

non-prescription medications You have taken since January 26, 2006, and please include the name 

of the prescriber (if applicable), the date of the prescription (if applicable), the diagnosis or medical 

condition for which You took such medication or remedy, and the dates on which You took such 

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medication or remedy.

ANSWER: Julia refers Wells Fargo to her produced prescription records for 

05/22/2007 to 09/13/2021 (see JULIA’S MED RECS 03203-03322) and these records, along with 

Julia’s already produced medical records provide all of the information requested. See JULIA’S 

MED RECS 00001-03691.

INTERROGATORY NO. 9:

Have You had any Communications or discussions with any healthcare provider(s), 

Including mental healthcare provider(s), therapist(s), or counselor(s), about Your mental health or 

emotional well-being, Including stress, anxiety, or depression since January 26, 2006? If so, please 

Identify the healthcare provider(s) and state the date, location, and substance of Each such 

Communication or discussion.

ANSWER: Julia refers Wells Fargo to her already produced medical records and the 

any additional records produced as a result of Wells Fargo’s subpoenas in this case as containing 

all of the information responsive to this interrogatory. 

INTERROGATORY NO. 10:

Have You had any Communications or discussion with any healthcare provider(s), 

Including mental healthcare provider(s), therapist(s), or counselor(s), about Your mental health or 

emotional well-being Regarding Your ability to maintain full or part-time employment? If so, 

please Identify the healthcare provider(s) and state the date, location, and substance of Each such 

Communication or discussion.

ANSWER: Julia refers Wells Fargo to her already produced medical records and the 

any additional records produced as a result of Wells Fargo’s subpoenas in this case as containing 

all of the information responsive to this interrogatory. Further responding, Julia is sure she has 

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discussed 

these feelings with her primary care physician, Dr. Anita Pilai, and possibly other of her 

treating doctors.

INTERROGATORY NO. 11:

If You claim that Your Children experienced educational difficulties from the actions 

alleged in the Complaint, Identify the name and location of any school attended by Your 

Child(ren), and include the dates of attendance and the name(s) of Your Child(ren)’s teacher(s). 

ANSWER: Byron attended Lyons Township High School from approximately 2006-

2010. Miriahm attended Lyons Township High School from approximately 2008-2012. Byron 

attended National Louis University from approximately 2010 through approximately 2014 or 

2015. Miriahm attended National Louis University from 2012 through 2017.

INTERROGATORY NO. 12:

If You claim that Your Child experienced educational difficulties because of the actions

alleged in the Complaint, Identify the name and location of any school or post-secondary 

institution attended by Your Child, and include the dates of attendance, dates of withdrawal, the 

reason(s) for withdrawal, and the names of Your Child’s institution administrators who were 

involved in Your Child’s withdrawal process.

ANSWER: See Julia’s response to interrogatory 11 above. 

INTERROGATORY NO. 13:

If You claim that Your Child experienced educational difficulties at National Louis 

University because of the actions alleged in the Complaint, Identify the names of any of Your 

Child’s college/university roommates, college/university co-workers, and college/university 

residential assistants.

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ANSWER: Both Byron and Miriahm attended National Louis University, but never 

lived on campus. 

INTERROGATORY NO. 14:

If You claim that Your Children experienced educational difficulties from the actions 

alleged in the Complaint, Identify the name of Each healthcare provider, Including doctors, nurses, 

social workers, and counseling and mental health providers, who consulted with Your Child(ren) 

Regarding the problems Your Child(ren) experienced, and include the date of Each consultation, 

the reason(s) for Each consultation, the diagnosis made or result of the consultation, and the 

treatment(s) and solution(s) Communicated to You.

ANSWER: Julia objects to this Interrogatory on the basis that medical records were 

produced for Byron and Miriahm, and school records containing information regarding Miriahm’s 

hearing impairment were produced (see BYRON’S MED RECS 00001-00292; MIRIAHM’S 

MED RECS 00001-00840 and MIRIAHM’S SCHOOL RECORDS 00001-00210). Furthermore, 

Wells Fargo subpoenaed medical records and those records will contain all of the information 

requested in this Interrogatory.

INTERROGATORY NO. 15:

Identify Each lawsuit to which you have been a party, other than this action.

ANSWER: Asset Acceptance v. Julia Escamilla

Cook County Case No. 2010-M1-204569

GARCIA 01743-01784

Household Finance v. Julia Escamilla

Cook County Case No. 2009-M1-121723

GARCIA 01785-01787

Deutsche Bank vs. Garcias, et al.

2009-CH-00855

GARCIA 00015-00060

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In Re: Eduardo Garcia and Julia Escamilla

Chapter 7 Bankruptcy Case No. 11-22208

GARCIA 00061-00113

INTERROGATORY NO. 16:

Identify and itemize all elements of damages, past or future, You claim or allege to be 

caused by Wells Fargo in this Action, and as to Each, Identify the amount claimed, the method, if 

any, by which You computed the amount, the figures used in that computation, and the facts and 

assumptions upon which your claim is based.

ANSWER: Julia objects to this interrogatory on the grounds that the damages claimed 

are unliquidated and within the province of the jury to determine. Without waiving said objection, 

and solely for the edification and understanding of Wells Fargo regarding the various ways in 

which Wells Fargo’s action caused massive needless harm to Julia, the following information is 

provided relative to Julia’s claims:

Actual Damages:

Non-Economic Damages: 

● Emotional Distress damages including: 

▪ Mental Anguish associated with the loss of the family’s home, 

▪ Shame associated with the loss of the family’s home, 

▪ fear of being homeless, 

▪ disruption of the parental relationship with her children, 

▪ the loss of her daughter’s dogs, which ultimately proved temporary, but was 

especially difficult for Miriahm, 

▪ disruption of her marital relationship with Eduardo, 

▪ embarrassment over the loss of the Family Home, 

▪ feelings of failure associated with the loss of the Family Home, 

▪ interference with her spiritual and church relationships, 

▪ depression, 

▪ stress, 

▪ anxiety, 

▪ worry, 

▪ loss of sense of place, 

▪ loss of what she considered a meeting space for the family’s church 

community, the family home had become the go-to space for their church 

members, bible studies, and youth meetings. Not to mention the favorite 

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hangout for the children and their friends. Over the years it had become a 

weekly tradition for the bible study group to meet at the Family Home, 

and also a favorite hangout location for the church youth. They would 

pray, sing, practice musical instruments. The Family Home was 

considered a safe space for the meetings by the Garcias’ church family and 

the Garcias. In fact, at one point the Garcias decided to eliminate a wall 

between the dining room and living room to create an open concept 

specifically because of the meetings in the Family Home. This all ended 

when Wells Fargo took the Garcias’ Family Home and the Garcias moved 

to the Brookfield apartment. 

▪ increased isolation, 

▪ loss of keepsakes and heirlooms, 

▪ the distress of watching Eduardo’s mental state sink deeper into despair, 

▪ The anguish of having all the needless harms associated with losing the 

Family Home explode come washing back over her after receiving the first 

Wells Fargo letter in 2019, 

▪ Anger associated with learning her family never should have suffered these 

losses;

▪ the destruction of Julia’s American Dream; 

Bodily Injury, Pain and Suffering: 

The bodily injuries and pain and suffering resulting from the medical conditions 

which were caused by, or result from, or were otherwise exaggerated, increased, 

exacerbated, or caused to be made worse because of Wells Fargo’s conduct, 

including, but not limited to causing or worsening of her major depressive 

disorder, fibromyalgia, and migraines. 

Julia has no training or expertise by which she could value the needless harms Wells 

Fargo has inflicted upon her in this case. Julia is relying upon her counsel to set the 

value of her non-economic injuries. Julia’s counsel will ask the jury to award $200 

per hour for her non-economic damages. As of March 5, 2022, that number is 

101,064 hours. As of March 5, 2022, that calculation is $20,212,800 and increasing 

every day. 

Economic Damages: 

● Severe damage to her credit rating; 

● Inability to access credit to purchase a reliable automobile; 

● Inability to access significant parts of the housing market after foreclosure; 

● Legal fees for filing of Chapter 7 = $1,750.00; Chapter 7 filing fee = $299.00 

● Loss of potential equity = $182,586.00 through the complaint date. This number 

is almost certain to increase by the time of trial. 

● Approximately $1000-1500 in application fees for apartments after Wells Fargo 

took their Family Home. 

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● Loss of personal property such as furnishings and appliances the family was 

forced to give away after the foreclosure. 

● Significant time spent working on a loan modification. 

● Costs of making copies and mailing information to Wells Fargo for loss 

mitigation efforts. 

● Increased maintenance costs required to maintain the older, cheaper, and less 

reliable vehicles the family drove because their credit prevented them from 

purchasing something more reliable. 

● Loss of the Family Home the Garcias expected to pass to their children or 

grandchildren. 

● Legal fees and costs for preparing/filing/prosecuting this action. The Garcias 

object to the production of these documents at this time on the basis of attorneyclient privilege and work product doctrine. Documents will be produced as may 

be ordered by the Court for an award of attorney fees. These attorney’s fees will 

not be claimed in the case in chief, rather, if the Plaintiff prevails then counsel 

will seek fees under the ICFA.

INTERROGATORY NO. 17:

Explain in detail the basis for the discrepancy between Your allegation in paragraph 67 of 

the Complaint and Your subpoena response to Request for Production of Documents 8, dated 

November 16, 2021.

ANSWER: There is no discrepancy. At the time of filing the Complaint, we had not 

been able to fully itemize the total we spent on improvements to the Family Home. We knew we 

had invested “over $40,000 and extensive time in completely rehabbing” the Family Home. In 

responding to Wells Fargo’s Request for Production No. 8, we completed the itemization of those 

costs, and we totaled the costs to an estimated $66,850.00. 

INTERROGATORY NO. 18:

Explain in detail the basis of Your contention that Wells Fargo caused Your Child, Byron 

Garcia, to not to attend “DePaul University or College of DuPage,” or to “never ... finish and 

obtain a college degree” as alleged in paragraph 115(O) of the Complaint.

ANSWER: College of DuPage charges a significantly reduced “in-district” tuition to 

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students that reside in their District. Our Family Home was in this District for reduced tuition. 

After Wells Fargo took our Family Home, we no longer lived in the District to receive discounted 

tuition. College of DuPage is a community college with a very good reputation. I believe College 

of Dupage is the type of college where Byron could have thrived. After Wells Fargo took our 

Family Home, Byron told me he was concerned about being a financial burden on his parents and 

the costs of college became a primary concern for him. Byron no longer believed we could provide 

him any help financially with the costs of college. After Wells Fargo took our Family Home, Byron 

lost focus on college and had a number of issues prior to quitting college and going to work. I 

believe Byron would have flourished and done well in college if Wells Fargo had not taken our 

Family Home. Byron was changed by the loss of our Family Home and never had the same attitude 

about college after that loss. 

INTERROGATORY NO. 19:

Explain in detail the basis of Your contention that Wells Fargo caused You 

“embarrassment, humiliation, shame” and “feelings of failure” as alleged in paragraph 115(S)(h) 

of the Complaint.

ANSWER: My work has always been in helping my community. Inside my programs, 

we had partnerships with community organizations to educate our community on good health and 

sound finances. We had partnerships with organizations such as The Resurrection Project and 

Instituto del Progreso Latino on managing budgets, organizing finances, and how to buy your first 

home. I found myself in the embarrassing position of trying to educate the community in subjects 

where I felt that I had failed. I also led a team of up to twenty employees and a database of 700 

volunteers on these projects. I was supposed to be the motivational leader on educating the 

community in these areas. Instead, after Wells Fargo took our Family Home, I was in the position 

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of telling my staff, our volunteers, and other community organization partners to come and take 

things from my Family Home that we could not take with us because Wells Fargo had taken our 

Family Home. I was traumatized and embarrassed. I will never forget that experience or the 

feelings of failure, shame, humiliation, and embarrassment that I felt. I am haunted by this 

experience even to this day.

I also felt incredible shame seeing my children lose many of their personal possessions 

they had accumulated over the years. I blamed myself for losing our Family Home until I received 

Wells Fargo’s letters in 2019 and met with my attorney. All that time I felt and believed that I had 

failed as a mother, wife, protector, and provider. I believed I had failed my children and my 

husband. I believed that I had failed Eduardo when he needed me the most and there was nothing 

I could do to relieve the depression and despair he was feeling because of the loss of our Family 

Home.

I also felt like I was a criminal or a thief having the Court order me to vacate my family’s 

home. I felt like I was being chased away from our Family Home. From the time Wells Fargo took 

our Family Home until I received the letters from Wells Fargo and talked to my lawyer, I felt 

incredible shame whenever I was around any friends and family who knew what we had 

experienced. Prior to losing our Family Home, we had been the part of our extended family who 

had achieved the American Dream. We had purchased a nice home, which we had worked hard to 

improve, in a nice neighborhood with good schools in a safe area. 

Losing our Family Home made me feel like we were being chased away from this place of 

shelter and security because we didn’t belong. Going around my extended family and friends just 

increased my sense of shame, humiliation, and feelings of failure. I felt like I had become a bad 

role model to my children. For me, the the goal of homeownership was not the “American dream.” 

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My American dream was always to build a Family Home for myself and my family. I always 

dreamed of a safe place, where I could teach my children to be hardworking, happy, and 

successful. I was and I am devastated by the loss of our Family Home. I was in shock after Wells 

Fargo took our Family Home. I believed I had lost my American Dream and completely failed 

everyone that I loved.. Since Wells Fargo took our family’s home, I have regretted the efforts I put 

into trying to find our place. Until I received Wells Fargo’s letters in 2019, I felt my efforts had 

been the wrong choice and had put my family into a nightmare and destroyed our lives financially. 

If I had known that Wells Fargo was going to take our Family Home the way they did, I would 

have never chosen home ownership. I would have never allowed my family to suffer the things 

they have suffered because of Wells Fargo. 

Prior to losing our Family Home, I thought of myself as extremely blessed with what I had 

accomplished, with a positive future and a wonderful career. Losing our Family Home destroyed 

my belief in myself and my self-worth. I questioned everything I thought was real. I doubted my 

own abilities and qualifications for my career, I felt like a complete failure to my husband and my 

children, and I became overwhelmed.

INTERROGATORY NO. 20:

Explain in detail the basis of Your contention that Wells Fargo caused Your “Major 

Depressive Disorder,” “fibromyalgia,” “extreme migraines,” and “marriage to Mr. Garcia [suffer] 

and [deteriorate]” as alleged in paragraph 115(T)(a), (b), (c), and (f) of the Complaint.

ANSWER: I was diagnosed with Major Depressive Disorder in or about 2008 (see

JULIA’S MED RECS 02438). I was diagnosed with fibromyalgia in or about 2005 (see JULIA’S 

MED RECS 01971). I was diagnosed with migraines in or around 1994, but with treatment they 

had all but gone away by approximately 2004. However, they returned when the issues with our 

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Family Home began. The migraines have not gone away completely since. (see JULIA’S MED 

RECS 01706). 

My health was greatly affected during the years between 2008 and 2010 while Wells Fargo 

was pursuing foreclosure on our Family Home. I was working frantically and constantly trying to 

get a loan modification to save our Family Home. 

My physical and mental health continued to deteriorate in the years after Wells Fargo took 

our Family Home. I have never fully recovered from the loss of our Family Home. I have never 

been the same person since the loss of our Family Home. My health has deteriorated since that 

time. As my health problems worsened, I could no longer perform my job duties. I had loved my 

job, but the sense of failure I felt from the loss of our Family Home and my failing health prevented 

me from performing my job at the level that the community and my colleagues deserved. 

I used to be motivated and inspired by the stress and demands of the job. My work would 

energize, motivate, and invigorate me. After the loss of our Family Home, the stress and demands 

just made my health problems and my mental state worse. I was constantly in pain. I was always 

tired, unmotivated, sad, depressed, and just generally unhappy. For all these reasons, I believed I

was failing in my work just as I had failed my family and I resigned my job at Alivio and my career 

in this field in September 2012. I believed my community and my colleagues deserved better than 

I could give them after the loss of our Family Home. 

My medical conditions were aggravated by stress. I experienced overwhelming stress 

around the experience of trying to secure a loan modification from Wells Fargo and then Wells 

Fargo taking our Family Home. The fibromyalgia I was suffering with was aggravated by the 

lifting, packing and living out of boxes that we experienced after Wells Fargo took our family’s 

home (see JULIA’S MED RECS 01689), and by the energy and time it took to find an apartment 

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to live in afterwards. I believe that the anxiety, shame, grief, and embarrassment I felt around 

Wells Fargo’s taking of our Family Home impacted all of my health conditions. I believe we did 

all we could to save our Family Home. We communicated with Wells Fargo regularly. We would 

send and then re-send everything Wells Fargo asked us to provide to obtain a loan modification. 

Every day of this process I experienced significant stress around our efforts to save our Family 

Home. 

The thought of losing our Family Home caused tension between myself and Eduardo. The 

tension between us as a couple spilled over onto our children and our relationship with them. We 

were so consumed with trying to save our Family Home and then the pain of losing our Family 

Home that our children suffered and our relationships with our children were weakened. Every 

member of my family, and every one of our relationships with one another was damaged and 

weakened by this experience. Our Family Home was a happy, safe, and secure place. Our lives 

have not been the same since Wells Fargo took that from us. During the time we were fighting for 

our Family Home and in the aftermath of losing our Family Home, Eduardo and I were less 

tolerant, patient, and flexible with each other. I was suffering myself and was also watching 

Eduardo suffer in his own way, and I saw how my children were suffering. While all of this was 

happening, the symptoms and pain from my fibromyalgia and chronic migraines became worse 

and I became more and more depressed. 

After my family received Wells Fargo’s letters in 2019, I felt like every ounce of pain, 

stress, worry, and anxiety I had experienced almost a decade earlier hit me again with full force. I 

really cannot put into words the hurt, sorrow, and great sadness I feel knowing that Wells Fargo 

took my Family Home instead of giving us the loan modification we begged for at that time. It is 

hard to even try to describe how learning of Wells Fargo’s mistake has impacted me. Since 

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receiving Wells Fargo’s letter in 2019, my suffering has been magnified by knowing everything 

my family went through should have never happened. Since receiving Wells Fargo’s 2019 letter, 

I have suffered significant stress, anger, anxiety, frustration, crying spells, sleepless nights, and 

inconsolable sadness. I am consumed by thoughts of how much different my family’s life could 

have been if Wells Fargo had not taken our Family Home. I think about the nightmare we lived 

through for more than a decade because of Wells Fargo and how my family has suffered. I try not 

to let these thoughts overwhelm me. Despite my efforts not to dwell on what Wells Fargo did to 

my family, I do believe Wells Fargo’s conduct is a major factor in my deteriorating health. I cannot 

shake the fact that this nightmare that has caused so much harm to my family was completely 

avoidable. 

INTERROGATORY NO. 21:

Explain in detail the basis of Your contention that Wells Fargo caused Your Child, Byron 

Garcia, “trauma” as alleged in paragraph 115(V)(f) and (g) of the Complaint.

ANSWER: Byron can best answer fully how he believes this has impacted him. I saw 

how the loss of our Family Home impacted Byron. I saw how the damage to our family 

relationships changed Byron. I saw Byron’s attitude about his own future and his own plans 

change. I saw Byron be put into positions of acting as an adult when he was still a child. And I 

observed how Byron suffered over the loss of our Family Home. My child experienced stress, 

worry, fear, and anxiety he should have never had to experience. My child experienced bouts of 

sadness and depression that he should have never experienced. My son was changed by this 

experience and his attitude towards life and his future is different because of Wells Fargo. 

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Dated: March 7, 2022 Respectfully submitted,

/s/ Nick Wooten

Nick Wooten 

NICK WOOTEN, LLC

5125 Burnt Pine Drive

Conway, Arkansas 72034

(833) 937-6389

nick@nickwooten.com

Rusty A. Payton,

PAYTON LEGAL GROUP

20 North Clark Street, Suite 3300

Chicago, Illinois 60602

(773) 682-5210

info@payton.legal

Salvador J. Lopez

ROBSON & LOPEZ, LLC

180 W. Washington Street, Suite 700

Chicago, Illinois 60602

312-523-2166

lopez@robsonlopez.com

Counsel for the Plaintiffs

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CERTIFICATE OF SERVICE

I certify that on March 7, 2022, a copy of the foregoing Julia Garcia’s Answers to 

Defendant Wells Fargo Bank, N.A.’s First Set of Interrogatories 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

/s/ Nick Wooten

Nick Wooten

Redact

Case: 1:20-cv-02402 Document #: 78-3 Filed: 04/11/22 Page 20 of 20 PageID #:772