EXHIBIT 1

Case: 1:20-cv-02402 Document #: 50-1 Filed: 11/01/21 Page 1 of 20 PageID #:431
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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ANDREW J. MAXWELL, not individually, 

but as Trustee for the estate of Eduardo Garcia 

and Julia Escamilla (nka Julia Garcia), et al.

Plaintiffs,

vs. 

WELLS FARGO BANK, N.A., 

Defendant.

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Case No. 1:20-cv-02402 

Judge Rebecca R. Pallmeyer

Judge Heather K. McShain 

DEFENDANT WELLS FARGO BANK, N.A.’S SUPPLEMENTAL OBJECTIONS AND 

RESPONSES TO PLAINTIFF’S FIRST SET OF INTERROGATORIES

Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant Wells Fargo Bank, 

N.A. (“Defendant”) hereby supplements its objections and responses to Plaintiff Andrew 

Maxwell’s (“Plaintiff”) First Set of Interrogatories. Defendant reserves the right to further 

supplement, modify, or amend these responses up to and through the time of trial. 

DEFENDANT’S RESPONSE TO INTERROGATORIES

Fully identify each and every person with whom You consulted, spoke, corresponded, or 

otherwise conferred in providing any information or documents with respect to the answers to 

these interrogatories, requests to produce, and requests to admit, and indicate for which 

interrogatory, request to produce, and request to admit each person was consulted. 

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege. Defendant further objects to this Interrogatory on the ground that it 

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is overbroad, unduly burdensome, oppressive, and not proportional to the needs of the case. 

Defendant also objects to this Interrogatory on the ground that it seeks information that is not 

relevant to the claims and defenses in this case. 

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege. Defendant further objects to this Interrogatory on the ground that it 

is overbroad, unduly burdensome, oppressive, and not proportional to the needs of the case. 

Defendant also objects to this Interrogatory on the ground that it seeks information that is not 

relevant to the claims and defenses in this case. 

Subject to the foregoing objections, Defendant responds: Wells Fargo states that the person 

identified in the verification will validate these responses on behalf of Wells Fargo, which were 

prepared based on the business records of Wells Fargo, and with the assistance of in-house and 

outside counsel at Winston & Strawn LLP. This individual may only be contacted through 

undersigned counsel. Wells Fargo anticipates designating a corporate representative to discuss 

specific topics at deposition, trial, or evidentiary hearing, as may be appropriate.

Identify each loan modification application made by the Garcias between February 1, 2008 

and February 18, 2011, stating the date each application was received, listing any correspondence 

you sent to the Garcias while each application was pending, the type(s) of loan modification or 

loss mitigation option(s) for which the Garcias were considered on each application, and the date 

the Garcias were notified of each denial. 

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Defendant objects to this Interrogatory on the ground that it is overbroad, unduly 

burdensome, oppressive, and not proportional to the needs of this case. 

Subject to and without waiving these objections, Defendant states the following: Defendant 

will produce the Garcia’s Loan File in response to this Interrogatory. 

Identify the date of submission of the Garcias’ loan modification application that is the 

subject of the July 26, 2019 letter (Exhibit B to Plaintiffs’ Complaint).

Defendant objects to this Interrogatory on the ground that it seeks information in the 

possession of, known to, or otherwise equally available to Plaintiff.

Subject to and without waiving these objections, Defendant responds that the Garcias’ loan 

modification application that is the subject of the July 26, 2019 letter was submitted on April 23, 

2010.

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 3

Defendant objects to this Interrogatory on the ground that it seeks information in the 

possession of, known to, or otherwise equally available to Plaintiff.

Subject to and without waiving these objections, Defendant responds that the Garcias’ loan 

modification application that is the subject of the July 26, 2019 letter was submitted on April 22

and April 23, 2010.

Identify by name, job title and business address, all Wells Fargo employees who worked 

on the application identified in Interrogatory No. 3. For purposes of this Interrogatory, if any 

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employee identified is no longer employed with Wells Fargo, please state the date of termination 

of employment with Wells Fargo and provide your last contact information in Your possession to 

include the employee’s last known name, address, phone number and any personal email account.

Defendant objects to this Interrogatory as harassing. Defendant further objects to this 

Interrogatory on the ground that it is overbroad, unduly burdensome, oppressive, and not 

proportional to the needs of the case. Defendant also objects to this Interrogatory on the ground 

that it seeks information that is not relevant to the claims and defenses in this case. Defendant 

further objects to the Interrogatory on the ground that it seeks information the disclosure of which 

would invade the privacy of third parties. Defendant also objects to this Interrogatory on the 

ground that it is impermissibly compound.

Identify all third-party providers who worked on and/or provided any service related to the 

Garcias’ application identified in Interrogatory No. 3. For purposes of this Interrogatory, please 

identify the specific task(s) performed by each third-party.

Defendant objects to this Interrogatory as harassing. Defendant further objects to this 

Interrogatory on the ground that it is overbroad, unduly burdensome, and disproportionate to the 

claims and defenses in this case. Defendant also objects to this Interrogatory on the ground that it 

seeks information that is not relevant to the claims and defenses in this case. Defendant further 

objects to this Interrogatory as vague and ambiguous as to the term “third-party providers.”

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SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 5 

Defendant objects to this Interrogatory as harassing. Defendant further objects to this 

Interrogatory on the ground that it is overbroad, unduly burdensome, and disproportionate to the 

claims and defenses in this case. Defendant also objects to this Interrogatory on the ground that it 

seeks information that is not relevant to the claims and defenses in this case. Defendant further 

objects to this Interrogatory as vague and ambiguous as to the term “third-party providers.”

Subject to and without waiving these objections, Defendant responds that it has no

responsive information for Interrogatory No. 5. 

Identify the software and/or mortgage loan modification underwriting tool that Wells Fargo 

used from February 1, 2008 to February 18, 2011 in determining whether the Garcias met threshold 

requirements for a mortgage loan modification.

Defendant objects on the ground that the terms “identify” and “underwriting tool” are 

vague and ambiguous. Defendant also objects to this Interrogatory on the ground that it seeks 

information that is not relevant to the claims and defenses in this case. Defendant further objects 

to this Interrogatory on the ground that it is overbroad and disproportionate to the claims and 

defenses in this case. Defendant also objects to this Interrogatory to the extent it seeks confidential 

and proprietary information.

Subject to and without waiving these objections, Defendant states that from approximately

April 2010 and continuing through the decisions with respect to Plaintiffs’ loans, it used an 

automated mortgage loan modification underwriting tool (Wells Fargo’s “HPA Tool”) to 

determine its customers’ eligibility for government-mandated mortgage modifications.

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Identify the date upon which Wells Fargo first became aware of the error in its mortgage 

loan modification underwriting tool that led to Wells Fargo’s denial of the Garcias’ loan 

modification.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work-product protection. Defendant further objects to this 

Interrogatory on the ground that the term “became aware of” is vague and ambiguous.

SUPPLEMENTAL RESPONSE TO INTEROGATORY NO. 7

Defendant objects on the ground that the terms “identify” and “underwriting tool” are 

vague and ambiguous. Defendant also objects to this Interrogatory on the ground that it seeks 

information that is not relevant to the claims and defenses in this case. Defendant further objects 

to this Interrogatory on the ground that it is overbroad and disproportionate to the claims and 

defenses in this case. Defendant also objects to this Interrogatory to the extent it seeks confidential 

and proprietary information.

Subject to and without waiving these objections, Defendant states that from approximately 

April 2010 and continuing through the decisions with respect to the Garcias’ loan on August 24, 

2010, it used an automated mortgage loan modification underwriting tool (Wells Fargo’s “HPA 

Tool”), which stands for Home Preservation Application, to determine its customers’ eligibility 

for government-sponsored mortgage modifications.

Explain in detail how Wells Fargo determined and calculated the amount of the July 26, 

2019 check issued to the Garcias (Exhibit B to Plaintiffs’ Complaint).

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Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work-product protection. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant further objects to this Interrogatory on the ground that it is 

overbroad, unduly burdensome, oppressive, and not proportional to the needs of this case.

Defendant also objects to this Interrogatory on the ground that it seeks information that is not 

relevant to the claims and defenses in this case. 

Explain in detail how Wells Fargo determined and calculated the amount of the November 

18, 2019 check issued to the Garcias (Exhibit C to Plaintiffs’ Complaint).

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work-product protection. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant further objects to this Interrogatory on the ground that it is 

overbroad, unduly burdensome, oppressive, and not proportional to the needs of this case. 

Defendant also objects to this Interrogatory on the ground that it seeks information that is not 

relevant to the claims and defenses in this case. 

Explain in detail the process, including all calculations, that You used when You denied 

the Garcias’ loan modification described in Interrogatory No. 3, specifically indicating the errors 

in the calculations.

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Defendant objects to this Interrogatory on the ground that it is overbroad, unduly 

burdensome, oppressive, and not proportional to the needs of this case. Defendant further objects 

to the Interrogatory as vague and ambiguous as to the term “process.” Defendant also objects to 

this Interrogatory to the extent it seeks confidential and proprietary information.

Subject to and without waiving these objections, Defendant states: Defendant will produce 

documents that include information responsive to this Interrogatory.

Explain in detail Your denial of paragraph 31 of Plaintiffs’ Complaint.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant also objects to this Interrogatory on the ground that it is 

compound, overbroad, unduly burdensome, oppressive, and not proportional to the needs of the 

case. Defendant also objects to this Interrogatory on the ground that it seeks information that is 

not relevant to the claims and defenses in this case. Defendant further objects to this Interrogatory

on the ground that it is premature at this stage in the litigation.

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 11

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant also objects to this Interrogatory on the ground that it is 

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compound, overbroad, unduly burdensome, oppressive, and not proportional to the needs of the 

case. Defendant also objects to this Interrogatory on the ground that it seeks information that is 

not relevant to the claims and defenses in this case. Defendant further objects to this Interrogatory 

on the ground that it is premature at this stage in the litigation.

Subject to and without waiving these objections, Defendant states: Wells Fargo did detect 

a calculation error regarding foreclosure attorneys’ fees affecting certain accounts that were in the 

foreclosure process between April 13, 2010, and October 2, 2015, when the error was corrected. 

Explain in detail Your denial of paragraph 32 of Plaintiffs’ Complaint.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant objects to this Interrogatory 

on the ground that it is compound, overbroad, unduly burdensome, oppressive, and not 

proportional to the needs of the case. Defendant also objects to this Interrogatory on the ground 

that it seeks information that is not relevant to the claims and defenses in this case. Defendant 

further objects to this Interrogatory on the ground that it is premature at this stage in the litigation.

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 12

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant objects to this Interrogatory 

on the ground that it is compound, overbroad, unduly burdensome, oppressive, and not 

proportional to the needs of the case. Defendant also objects to this Interrogatory on the ground 

that it seeks information that is not relevant to the claims and defenses in this case. Defendant 

further objects to this Interrogatory on the ground that it is premature at this stage in the litigation. 

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Subject to and without waiving these objections, Defendant states: Wells Fargo needed to 

develop its own software tool to determine borrower eligibility for the HAMP loan modifications 

at issue. The software tool provided by the government for mortgage servicers to use in 

determining whether Family Homeowners met certain threshold requirements did not contain an 

equivalent decisioning module. 

Explain in detail Your denial of paragraph 33 of Plaintiffs’ Complaint.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant also objects to this Interrogatory on the ground that it seeks 

information that is not relevant to the claims and defenses in this case. Defendant objects to this 

Interrogatory on the ground that it is compound, overbroad, unduly burdensome, oppressive, and 

not proportional to the needs of the case. Defendant further objects to this Interrogatory on the 

ground that it is premature at this stage in the litigation.

Explain in detail Your denial of paragraph 36 of Plaintiffs’ Complaint.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant objects to this Interrogatory 

on the ground that it is compound, overbroad, unduly burdensome, oppressive, and not 

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proportional to the needs of the case. Defendant further objects to this Interrogatory on the ground 

that it is premature at this stage in the litigation.

Explain in detail Your denial of paragraph 47 of Plaintiffs’ Complaint.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant also objects to this Interrogatory on the ground that it seeks 

information that is not relevant to the claims and defenses in this case. Defendant objects to this 

Interrogatory on the ground that it is compound, overbroad, unduly burdensome, oppressive, and 

not proportional to the needs of the case. Defendant further objects to this Interrogatory on the 

ground that it is premature at this stage in the litigation.

Explain in detail Your denial of paragraph 51 of Plaintiffs’ Complaint.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant also objects to this Interrogatory on the ground that it seeks 

information that is not relevant to the claims and defenses in this case. Defendant also objects to 

this Interrogatory on the ground that it is compound, overbroad, unduly burdensome, oppressive, 

and not proportional to the needs of the case. Defendant also objects to this Interrogatory to the 

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extent it seeks confidential and proprietary information. Defendant further objects to this 

Interrogatory on the ground that it is premature at this stage in the litigation.

Explain in detail Your denial of paragraph 125 of Plaintiffs’ Complaint.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant objects to this Interrogatory on the ground that it is compound, 

overbroad, unduly burdensome, oppressive, and not proportional to the needs of the case. 

Defendant further objects to this Interrogatory on the ground that it is premature at this stage in 

the litigation.

Explain in detail Your denial of paragraph 126 of Plaintiffs’ Complaint. 

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant objects to this Interrogatory 

on the ground that it is overbroad, unduly burdensome, oppressive, and not proportional to the 

needs of the case. Defendant further objects to this Interrogatory on the ground that it is vague 

and ambiguous as to the terms “conduct directed at consumers generally.” Defendant further 

objects to this Interrogatory on the ground that it is premature at this stage in the litigation.

Explain in detail Your denial of paragraph 127 of Plaintiffs’ Complaint.

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Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant objects to this Interrogatory 

on the ground that it is overbroad, unduly burdensome, oppressive, and not proportional to the 

needs of the case. Defendant further objects to this Interrogatory on the ground that it is vague 

and ambiguous as to the term “conduct.” Defendant further objects to this Interrogatory on the 

ground that it is premature at this stage in the litigation.

Explain in detail Your Sixth Defense (Good Faith). Specifically, explain in detail Your 

position that “the Bank at all times acted in good faith and honesty in fact, and always observed 

reasonable commercial standards of fair dealing in the trade, when dealing with the Garcias.”

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant objects to this Interrogatory 

on the ground that it is overbroad, unduly burdensome, oppressive, and not proportional to the 

needs of the case. Defendant further objects to this Interrogatory on the ground that it is premature 

at this stage in the litigation. 

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 20

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work product doctrine. Defendant objects to this Interrogatory 

on the ground that it is overbroad, unduly burdensome, oppressive, and not proportional to the 

needs of the case. Defendant further objects to this Interrogatory on the ground that it is premature 

at this stage in the litigation. 

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Subject to and without waiving these objections, Defendant states: Our Sixth Affirmative 

Defense is based upon the fact that as the Complaint admits, Wells Fargo did not act intentionally, 

but made a mistake, one that it publicly disclosed in 2018. It began a voluntary remediation 

program to assist affected borrowers, including the Garcias, in the fall of 2018. Wells Fargo sent 

the Garcias a letter notifying them of the mistake, stated Wells Fargo’s desire to make things right, 

enclosed a payment, offered to mediate, and informed them about a class action case. Wells Fargo 

eventually sent the Garcias a total of $24,500 in payments in an effort to remediate the error. 

Explain all efforts and investigations that Wells Fargo undertook to determine which 

consumers who were wrongfully denied a loan modification lost their home to foreclosure as a 

result of Wells Fargo’s denial for a loan modification.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work-product protection. Defendant further objects to this 

Interrogatory to the extent it seeks documents protected by the bank examination privilege. See 12 

C.F.R. § 4.36 et seq. Defendant further objects to this Interrogatory on the ground that it is 

overbroad, unduly burdensome, oppressive, not proportional to the needs of the case, and is not 

limited by any timeframe. Defendant also objects to the terms “efforts” and “investigations” as 

vague and ambiguous. Defendant also objects to this Interrogatory on the ground that it seeks 

information that is not relevant to the claims and defenses in this case. 

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Please identify each and every lay witness whom You reserve the right to call at trial, along 

with a summary of that individual’s anticipated testimony, full name, address, telephone number, 

and a copy of all documents provided by each witness to You or to such witness by You.

Defendant objects to the extent that the Interrogatory seeks information protected by the 

work product doctrine. Defendant objects to this Interrogatory on the ground that it is overbroad, 

unduly burdensome, oppressive, and not proportional to the needs of the case. Defendant further 

objects to this Interrogatory on the ground that it is prematurely seeking information relating to 

the anticipated testimony of “each and every lay witness [Defendant] reserve[s] the right to call at 

trial.” 

Subject to and without waiving the foregoing general and specific objections, Defendant

will provide a witness list at the time set forth by the applicable rules and pretrial orders issued in 

this case. 

Identify each and every document You reserve the right to utilize at trial, in any deposition, 

or during any hearing.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the work-product doctrine. Defendant objects to this Interrogatory on the ground that it is 

overbroad, unduly burdensome, oppressive and not proportional to the needs of the case. 

Defendant further objects on the ground that the Interrogatory is premature as to trial exhibit lists 

at this stage in the litigation. 

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Subject to and without waiving the foregoing general and specific objections, Defendant

will provide a trial exhibit list at the time set forth by the applicable rules and pretrial orders issued 

in this case. 

Identify each person employed or formerly employed by Wells Fargo, or who was an agent 

of Wells Fargo at any point, that was deposed in the Hernandez class action. For each person 

identified, state their full name, their position with Wells Fargo, a summary of their testimony and 

their last known contact information.

Defendant objects to this Interrogatory to the extent that it seeks information protected by 

the attorney-client privilege and/or work-product protection. Defendant also objects to this 

Interrogatory to the extent that it seeks documents or confidential material produced by Defendant 

in the Hernandez, et al. v. Wells Fargo & Company, et al. action that are prohibited from disclosure 

by a protective order. Defendant further objects to this Interrogatory on the ground that it is 

compound, overbroad, unduly burdensome, oppressive, and not proportional to the needs of the 

case. Defendant further objects to this Interrogatory on the ground that it seeks information that 

is not relevant to the claims and defenses in this case. Defendant further objects to this

Interrogatory on the ground that it seeks information the disclosure of which would invade the 

privacy of third parties.

List every document produced in the Hernandez class action by Wells Fargo that was not 

specific to an individual borrower. For each document listed, please identify the document, the 

author of the document, the purpose of the document and summarize the contents of the document. 

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Defendant also objects to this Interrogatory on the ground that documents produced by 

Defendant in the Hernandez, et al. v. Wells Fargo & Company, et al. action are prohibited from 

disclosure by a protective order. Defendant objects to this Interrogatory on the ground that it is 

overbroad, unduly burdensome, oppressive, and not proportional to the needs of the case. 

Defendant further objects to this Interrogatory on the ground that it seeks information that is not 

relevant to the claims and defenses in this case. 

Dated: October 29, 2021 Respectfully submitted,

Angela A. Smedley (pro hac vice) 

Winston & Strawn LLP 

200 Park Avenue 

New York, NY 10166 

Phone: 212-294-6700 

Fax: 212-294-4700 

asmedley@winston.com 

Shawn R. Obi (pro hac vice) 

Winston & Strawn LLP 

333 South Grand Avenue 

Los Angeles, CA 90071 

Phone: 213-615-1700 

Fax: 213-615-1750 

sobi@winston.com 

Counsel for Wells Fargo Bank, N.A. 

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the 29th day of October 2021, the foregoing was 

served upon the following:

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) 525-2166

lopez@robsonlopez.com

Nicholas H. Wooten

Nick Wooten, LLC

5125 Burnt Pine Drive

Conway, Arkansas 72034

(833) 937-6389

nick@nickwooten.com

Attorneys for Plaintiff

 /s/ Angela A. Smedley

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