MAURICE J. SMITH’S RESPONSES

1 Maurice J. Smith

18010 Kenwood Trail #115

2 Lakeview, MN 55044

3 (651) 592-5194

bigreese68@yahoo.com

Plaintiff, Pro Se

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF ILLINOIS

9 EASTERN DIVISION

11 Case No.: 11-14697

12 Chapter 7

JUDGE GOLDGAR

14 NO. 21-00041

MAURICE J. SMITH’S RESPONSES TO

19 UNITED STATES DEPARTMENT OF

EDUCATION’S FIRST SET OF

20 INTERROGATORIES AND REQUESTS

21 FOR THE PRODUCTION OF

DOCUMENTS

NOW COMES Plaintiff, Michael J. Smith, and hereby answers interrogatories propounded upon

24 him by Defendants, United States Department of Education and Governors State University, and

25 avers as follows:

ANSWERS

1 INTERROGATORY 1: Identify the Plaintiff’s, Plaintiff’s spouse/domestic partner, Plaintiff’s

2 Cohabitant(s), and Plaintiff’s dependent(s) dates of birth, their relationship to Plaintiff, and their

current principal residence address.

ANSWER 1: Plaintiff’s name is Maurice J. Smith, born on 03/26/1968. Plaintiff is divorced from

6 Ms. Maria Elena Valdez. Plaintiff has no dependents. Plaintiff’s address is 18010 Kenwood Trail

7 # 115, Lakeview, MN 55044.

8 INTERROGATORY 2: Identify each Income-producing Activity Plaintiff, Plaintiff’s

spouse/domestic partner, Plaintiff’s Cohabitant(s), and Plaintiff’s dependent(s) held at any time

since three years before Plaintiff’s Bankruptcy by stating the respective person’s (i) employer or

12 business name; (ii) address of the employer or business; (iii) job description; (iv) number of hours

13 of weekly Income-producing Activity; and (v) benefits provided by employer.

14 ANSWER 2: Plaintiff is an independent contractor working under his company name, Smith

Development Group, Inc. Plaintiff is a Valet Driver currently contracted to Driver Network Service

(DNS) at 4491 South SR 7, Suite 213, Davie, FL 33314. His pay is based on distance driven from

18 the dealership, not calculated by the hour. Plaintiff is also a freelance basketball official.

19 INTERROGATORY 3: State every source of income, revenue or support, other than Income-

20 producing Activities listed above, including but not limited to, any pension, disability

compensation, 401(k), individual retirement account, social security benefit, child support,

maintenance, trust, estate or other benefits or distribution from any source, to which Plaintiff,

24 Plaintiff’s spouse/domestic partner, Plaintiff’s Cohabitant(s), and Plaintiff’s dependents had any

25 right to a distribution since three years before the Bankruptcy, whether or not any distribution has

26 been received, by identifying the (i) payor’s name; (ii) payor’s address; and (iii) amount claimed

or entitled from each payor.

1 ANSWER 3: There is no source of income, revenue or support to which Plaintiff had any right to

2 distribution.

INTERROGATORY 4: For each checking, savings or other deposit account in which Plaintiff,

Plaintiff’s spouse/domestic partner, Plaintiff’s Cohabitant(s), or Plaintiff’s dependent(s) had any

6 interest since January 1, 2015, identify the (i) depository’s name; (ii) depository address; (iii)

7 account number; and (iv) nature of interest in each account.

8 ANSWER 4: The first depository is Wells Fargo located at 420 Montgomery Street, San Francisco,

CA 94104. The account numbers are 5312152845, 1722860929, 9236691045, 7283797574, and

Plaintiff is the owner of all accounts. The second depository is Navy Federal located

12 at 820 Follin Lane SE, Vienna, VA 22180. The account numbers are 7083015573, 7120848945,

13 3105064830, 7120373159, and 3145435313. Plaintiff is the owner of all accounts. The third

14 depository is First Tech Federal located at 5100 NE Dawson Creek Drive, Hillsboro, OR 97124.

The account number is 9342089829. Plaintiff is the owner of this account.

INTERROGATORY 5: For each credit card held by Plaintiff, Plaintiff’s spouse/domestic partner,

18 Plaintiff’s Cohabitant(s), or Plaintiff’s dependent(s) since January 1, 2015, identify (i) the issuer’s

19 name; (ii) the account number; and (iii) the time period during which the credit card was held.

20 ANSWER 5: Discover Card, account number 6011-0032-4939-1432 from March 2015 to

December 2020; AmEx, account number 349992627837**** from October 2018 to January 2019;

AmEx, account number 349992627866**** from October 2018 to January 2019; Commerce Bank,

24 account number 4873-0100-0128-7650 from October 2018 to January 2019; and Synchrony Bank,

25 account number 601918****** from March 2018 to January 2019.

26 INTERROGATORY 6: Identify each debt in excess of $250 that Plaintiff, Plaintiff’s

spouse/domestic partner, Plaintiff’s Cohabitant(s), or Plaintiff’s dependent(s) incurred or

1 reaffirmed since the Bankruptcy, by identifying the (i) creditor name; (ii) creditor address; (iii)

2 description of property or service purchased; and (iv) date the debt was reaffirmed or incurred.

ANSWER 6: The first creditor is Loan Me Inc. located at 1 City Boulevard West # 900, Orange,

CA 92868. Plaintiff took a loan that was incurred in February 2019. The second creditor is Itria

6 Ventures, LLC located at 1000 N West St. #1200, Wilmington, DE 19801. Plaintiff took a loan

7 that was incurred in April 2019. The third creditor is Ironwood Finance located at 800 N Shoreline

8 Blvd. #1500, Corpus Christi, TX 78401. Plaintiff took a loan that was incurred in April 2019. The

fourth creditor is ENGS Commercial Finance located at 1 Pierce PI #1100, Itasca, IL 60143.

Plaintiff obtained a tractor in November 2018.

12 INTERROGATORY 7: Identify every provider of health care, disability, workmen’s

13 compensation, and other insurance or benefit provider covering Plaintiff, Plaintiff’s

14 spouse/domestic partner, Plaintiff’s Cohabitant(s), or Plaintiff’s dependent(s), regardless of

policy’s ownership, by stating the (i) name of insurer or payor; (ii) address of insurer or payor; (iii)

insured policy number; and (iv) type of coverage.

18 ANSWER 7: The first insurer is Iowa Department of Human Services located at 822 Douglas St.,

19 Sioux City, IA 51101. The policy number for Medicaid Coverage is 3490092D. The second insurer

20 is Minnesota Department of Human Services located at 1 Mendota Rd. #100, West St. Paul, MN

The policy number for Medicaid Coverage is 7614208568.

INTERROGATORY 8: If Plaintiff, Plaintiff’s spouse/domestic partner, Plaintiff’s Cohabitant(s),

24 or Plaintiff’s dependents are or were a party (e.g., plaintiff, defendant, petitioner, respondent, or

25 claimant) in any case, administrative proceeding, mediation, or arbitration (state or federal),

26 including a proceeding for the dissolution of marriage or for workmen’s compensation claim, then

for each such case or proceeding, other than the Bankruptcy and this adversary proceeding, state

1 the (i) name of the case; (ii) docket or case number; and (iii) location of the court or administrative

2 board.

ANSWER 8: The name of the case is Smith v. Smith, 07D006729, Cook County, IL.

INTERROGATORY 9: If Plaintiff contends that Plaintiff’s, Plaintiff’s spouse’s/domestic

6 partner’s, Plaintiff’s Cohabitants’, or Plaintiff’s dependents’ physical or mental health is Related

7 to Plaintiff’s claim that the repayment of Plaintiff’s student loan(s) will impose an undue hardship

8 upon Plaintiff and/or Plaintiff’s dependent(s), then identify each Health Care Provider, who has

diagnosed, treated, or otherwise been consulted about each physical or mental health condition by

stating the (i) Health Care Provider’s name and address; (ii) date of diagnosis or treatment; and

12 (iii) patient’s name.

13 ANSWER 9: Neither Plaintiff’s nor his spouse’s/domestic partner’s, cohabitants’ or dependents’

14 physical or mental health is related to Plaintiff’s claim that the repayment of Plaintiff’s student

loan(s) will impose an undue hardship upon Plaintiff and/or his dependent(s).

INTERROGATORY 10: Complete the following schedule for Plaintiff’s, Plaintiff’s

18 spouse/domestic partner’s, Plaintiff’s Cohabitants’, and Plaintiff’s dependent(s)’s current income.

19 The amounts should reflect current income and deductions for each category.

1 INTERROGATORY 12: Identify each individual, by their name, address, and telephone number,

2 who may have knowledge or information about Plaintiff’s claims and defenses that Plaintiff

intends to rely upon in the above captioned adversary proceeding (including all persons who may

offer expert opinion at trial) and a summary of the subject matter of the knowledge or information

6 that could be elicited.

7 ANSWER 12: Maurice J. Smith of 18010 Kenwood Trail #115 , Lakeview, MN 55044, phone

8 number (651) 592-5194.

INTERROGATORY 13: If Plaintiff claims that forcing Plaintiff to repay Plaintiff’s student loans

held by the Department of Education will prevent Plaintiff and Plaintiff’s dependents from

12 maintaining a minimal standard of living due to financial circumstances that will continue for a

13 significant portion of the student loan repayment period, then describe every fact Plaintiff relies

14 upon in making that claim.

ANSWER 13: Plaintiff is completely unable to repay the student loans. His net income per month

is usually less than $500. Plaintiff has a housing voucher. He pays rent in the amount of $8 and

18 the government pays $934. With a net income of less than $500, it is untenable to expect Plaintiff

19 to pay his student loans which amount to more than $255,000.

20 INTERROGATORY 14: If Plaintiff claims that Plaintiff made good faith efforts to repay

Plaintiff’s student loans held by the United States Department of Education, then describe every

fact Plaintiff relies upon in making that claim.

24 ANSWER 14: Plaintiff has been unable to repay his student loans because his income is too low.

25 INTERROGATORY 15: For each motor vehicle in which Plaintiff, Plaintiff’s current

26 spouse/domestic partner, Plaintiff’s Cohabitant(s), or Plaintiff’s dependent(s) has an interest, state

the year, make, and model, the balance due for any financing secured by the vehicle, the current

1 mileage appearing on its odometer, the identity of who primarily uses the vehicle, and whether the

2 vehicle is used primarily for business or pleasure.

ANSWER 15: Plaintiff owns a 2014 Nissan Maxima with a mileage of 87,316 miles. There is no

balance due. Plaintiff uses the vehicle for pleasure.

6 INTERROGATORY 16: Identify any real property in which Plaintiff, Plaintiff’s current

7 spouse/domestic partner, Plaintiff’s Cohabitant(s), or Plaintiff’s dependent(s) has an interest,

8 provide an estimate of the value of such property and the basis for such valuation, and identify any

mortgage on such property by mortgagee and mortgage balance.

ANSWER 16: Plaintiff owns no real property.

13 REQUESTS

14 REQUEST 1: Produce Plaintiff’s income tax return and account transcripts for the tax years 2017,

2018, 2019, and 2020. A copy of IRS Form 4506-T, Request for Copy of Tax Transcript, which

can be used to request the transcripts, will be provided with these requests.

18 RESPONSE 1: After sending requests for production of the required documents to the relevant

19 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

20 documents once received.

REQUEST 2: Produce all Documents, dated since the Bankruptcy, Relating to Plaintiff’s,

Plaintiff’s spouse’s/domestic partner’s, Plaintiff’s Cohabitants’, or Plaintiff’s dependent(s)’s

24 Income-producing Activity.

25 RESPONSE 2: After sending requests for production of the required documents to the relevant

26 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

1 REQUEST 3: Produce all Documents, dated since the Bankruptcy, Relating to Plaintiff’s,

2 Plaintiff’s spouse/domestic partner’s, Plaintiff’s Cohabitants’, and Plaintiff’s dependent’s

retirements plans, including the most recent account statements of the Plaintiff’s periodic

contributions to and current account balance(s) of any Individual Retirement Accounts and 401(k).

6 RESPONSE 3: After sending requests for production of the required documents to the relevant

7 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

8 documents once received.

REQUEST 4: Produce all Documents, dated since the Bankruptcy, Relating to health care claims

and benefit payments, including but not limited to explanation of benefits, made on behalf of

12 Plaintiff, Plaintiffs spouse, Plaintiff’s Cohabitants, and Plaintiff’s dependent(s).

13 RESPONSE 4: After sending requests for production of the required documents to the relevant

14 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

REQUEST 5: Produce all Documents Relating to disability compensation, trust, or other revenue

18 source in which Plaintiff, Plaintiff’s spouses/domestic partners, Plaintiffs’ Cohabitants, or

19 Plaintiff’s dependent(s) have or expect to have an interest, regardless whether any distributions

20 have been made.

RESPONSE 5: After sending requests for production of the required documents to the relevant

bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

24 documents once received.

25 REQUEST 6: Produce all Documents Relating to each checking, saving or other deposit account,

26 including but not limited to bank statements, checkbook registers, and canceled checks, in any

bank, savings institution, cooperative, credit union, or other depository, in which Plaintiff,

1 Plaintiff’s spouse/domestic partner, Plaintiffs’ Cohabitants, or Plaintiff’s dependent(s) have or had

2 any interest and which is dated since January 1, 2018.

RESPONSE 6: After sending requests for production of the required documents to the relevant

bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

6 documents once received.

7 REQUEST 7: Produce all Documents, dated since January 1, 2018, Relating to each credit card

8 held by Plaintiff, Plaintiff’s spouse/domestic partner, Plaintiffs Cohabitants, or Plaintiff’s

dependent(s).

RESPONSE 7: After sending requests for production of the required documents to the relevant

12 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

13 documents once received.

14 REQUEST 8: Produce all Documents Relating to any investment, including mutual fund or

investment property, in which Plaintiff, Plaintiff’s spouse/domestic partner, Plaintiff’s Cohabitants,

or Plaintiff’s dependent(s) have or had any interest since the Bankruptcy.

18 RESPONSE 8: After sending requests for production of the required documents to the relevant

19 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

20 documents once received.

REQUEST 9: Produce all Documents Relating to all loans or other extensions of credit, including

loan applications, financial statements, asset lists, and credit reports, that Plaintiff, Plaintiff’s

24 spouse/domestic partner, Plaintiff’s Cohabitants, or Plaintiff’s dependent(s) applied for since the

25 Bankruptcy, whether or not any credit was extended.

26 RESPONSE 9: After sending requests for production of the required documents to the relevant

bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

1 documents once received.

2 REQUEST 10: Produce all Documents Relating to each purchase, lease, or other acquisition made

by Plaintiff, Plaintiff’s spouse/domestic partner, Plaintiff’s Cohabitants, or Plaintiff’s dependent(s)

since the Bankruptcy in which the item acquired cost at least $250.

6 RESPONSE 10: After sending requests for production of the required documents to the relevant

7 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

8 documents once received.

REQUEST 11: Produce all Documents Relating to each sale, gift, or other transfer of property

made by Plaintiff, Plaintiff’s spouse/domestic partner, Plaintiff’s Cohabitants, or Plaintiff’s

12 dependent(s), since the Bankruptcy, in which item transferred cost $250 or more.

13 RESPONSE 11: After sending requests for production of the required documents to the relevant

14 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

REQUEST 12: Produce all Documents Relating to Plaintiff’s, Plaintiff’s spouse’s/domestic

18 partner’s, Plaintiff’s Cohabitants’, or Plaintiff’s dependents’ purchase and/or financing of any

19 motor vehicles since the Bankruptcy, including the bill of sale, application for financing,

20 reaffirmation agreement, and the most recent insurance premium statement.

RESPONSE 12: After sending requests for production of the required documents to the relevant

bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

24 documents once received.

25 REQUEST 13: Produce all Documents Relating to all court cases and administrative proceedings,

26 including all pleadings, discovery, orders, judgment, and decrees in which Plaintiff, Plaintiff’s

spouse/domestic partner, Plaintiff’s Cohabitants, or Plaintiff’s dependent(s) is/were a party,

1 including but not limited to, the dissolution of marriage, property settlement agreement, or

2 prenuptial agreement, and records of payments of all maintenance, alimony, child support, and

other orders of support in which Plaintiff, Plaintiff’s spouse, Plaintiff’s Cohabitants, or Plaintiff’s

dependent(s) have or expect to have a right to or obligation for support, regardless whether any

6 distributions have been made.

7 RESPONSE 13: After sending requests for production of the required documents to the relevant

8 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

REQUEST 14: Produce a copy of Plaintiff’s transcript of grades and credits from each post-

12 secondary educational institution that Plaintiff attended.

13 RESPONSE 14: After sending requests for production of the required documents to the relevant

14 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

REQUEST 15: If Plaintiff contends that Plaintiff’s, Plaintiff’s spouse’s/domestic partner’s,

18 Plaintiff’s Cohabitants’, or Plaintiff’s dependent(s)’s health, whether physical or mental, renders

19 the Plaintiff’s repayment of Plaintiff’s student loan(s) an undue hardship upon Plaintiff, then

20 produce a complete copy of all medical records, including but not limited to correspondence,

opinions, prognosis, and reports of such medical condition.

RESPONSE 15: After sending requests for production of the required documents to the relevant

24 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

25 documents once received.

26 REQUEST 16: If Plaintiff contends that Plaintiff’s, Plaintiff’s spouse’s, Plaintiff’s Cohabitants’,

or Plaintiff’s dependent(s)’s health, physical or mental, render the repayment of the United States

1 Department of Education’s student loan(s) an undue hardship upon Plaintiff and Plaintiff’s

2 dependents, then provide each individual patient’s signature(s) on the enclosed Patient

Authorization to Release Medical Information and Patient Authorization to Release and Patient

Authorization to Release Psychotherapy Information (Plaintiff should sign for Plaintiff’s minor

6 dependents) whose health problem(s) form any part of the basis for Plaintiff’s undue hardship

7 claim, authorizing each Health Care Provider who provides health care to:

8 (a) furnish a complete copy of their chart or record of health care in their possession, including

any records generated by other Health Care Providers and in their possession;

(b) permit inspection of the original chart or record of health care during regular business hours

12 and at the regular business location of the Health Care Provider, upon written request made not

13 less than 7 days prior to the inspection;

14 (c) accept and consider charts and other records of health care by others, including reports,

deposition transcripts, and letters, furnished to the Health Care Provider before giving testimony

in any deposition or trial or other hearing; and

18 (d) confer with the United States Attorney and his assistants before giving testimony in any

19 deposition or trial or other hearing and engage in discussion with the attorney on the subjects of

20 the Health Care Provider’s observations related to the medical condition, including the following:

the medical history, whether charted or otherwise recorded or not; the Health Care Provider’s

opinions related to the state of health, prognosis, etiology, or cause for the state of health at any

24 time, and the nature and quality of care by other Health Care Providers, including whether any

25 standard of care was or was not breached; and the testimony the Health Care Provider would give

26 in response to any point of interrogation, and the education, experience, and qualifications of the

Health Care Provider.

1 RESPONSE 16: After sending requests for production of the required documents to the relevant

2 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

REQUEST 17: If Plaintiff relies upon Plaintiff’s, Plaintiff’s spouse’s/domestic partner’s,

6 Plaintiff’s Cohabitants’, or Plaintiff’s dependent(s)’s disability, for which the Social Security

7 Administration has awarded benefits, in making Plaintiff’s claim that the repayment of Plaintiff’s

8 student loan(s) imposes an undue hardship upon Plaintiff and Plaintiff’s dependents, then Plaintiff

is requested to have each social security beneficiary complete and sign the attached “Social

Security Administration Consent for Release of Information” in order to procure the submissions

12 made to and determinations made by the Social Security Administration.

13 RESPONSE 17: After sending requests for production of the required documents to the relevant

14 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

REQUEST 18: Produce all Documents Relating to each of Plaintiff’s burdens Plaintiff claims

18 renders an undue hardship upon Plaintiff to repay the student loans held by the United States

19 Department of Education.

20 RESPONSE 18: After sending requests for production of the required documents to the relevant

bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

documents once received.

24 REQUEST 19: Produce all Documents Relating to Plaintiff’s payments and credit applied against

25 Plaintiff’s student loans held by United States Department of Education.

26 RESPONSE 19: After sending requests for production of the required documents to the relevant

bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

1 documents once received.

2 REQUEST 20: Produce all Documents prepared and signed by each of Plaintiff’s retained or

specially employed experts, concerning Plaintiff or Plaintiff’s dependents’ health, containing the

following information:

6 (i) a complete statement of all opinions the witness will express and the basis and reasons for them;

7 (ii) the facts or data considered by the witness in forming them;

8 (iii) any exhibits that will be used to summarize or support them;

(iv) the witness’s qualifications, including a list of all publications authored in the previous 10

years;

12 (v) a list of all other cases in which, during the previous 4 years, the witness testified as an expert

13 at trial or by deposition; and

14 (vi) a statement of the compensation to be paid for the study and testimony in the case.

RESPONSE 20: After sending requests for production of the required documents to the relevant

bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

18 documents once received.

19 REQUEST 21: Produce all Documents prepared by Plaintiff’s expert(s), who is not retained or

20 specially employed to provide expert testimony in the above-captioned case, concerning Plaintiff

or Plaintiff’s dependents health, containing the following information:

(i) the subject matter on which the witness is expected to present evidence; and

24 (ii) a summary of the facts and opinions to which the witness is expected to testify.

RESPONSE 21: After sending requests for production of the required documents to the relevant

27 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

28 documents once received.

1 REQUEST 22: Produce all documents specified by Plaintiff in Plaintiff’s responses to the

2 Department of Education’s interrogatories, and all other documents that are relevant to, or were

consulted, referred to, or relied upon by Plaintiff in answering these interrogatories.

RESPONSE 22: After sending requests for production of the required documents to the relevant

6 bodies, Plaintiff hadn’t received at the time of filing these Responses. Plaintiff will avail the

7 documents once received.

8 REQUEST 23: Produce all documents that Plaintiff may or will offer at trial, regardless of whether

the documents will be offered into evidence.

RESPONSE 23: The requested documents are hereby attached.

Dated this 17th day of October, 2021.

2 I, Maurice J. Smith, being duly sworn depose and say that I am the Plaintiff in the above entitled

action, that I have read the foregoing Responses to United States Department of Education’s

First Set of Interrogatories and Requests for the Production of Documents, and know the

6 contents thereof. That the same is true of my own knowledge except as to those matters and

7 things stated upon information and belief, and as to those things, I believe them to be true.

(Sign in the presence of a Notary Public)

Sworn to and subscribed before me this day of , 2021.

13 Notary Public

(Printed name of Notary Public)

My Commission Expires:

1 CERTIFICATE OF SERVICE

2 I hereby certify that a true and correct copy of the foregoing document was sent on the 17th day

of October, 2021 via electronic mail and further mailed a copy via USPS first class mail to the

following parties or attorneys of record:

6 John R. Lausch Jr.

7 United States Attorney David H. DeCelles

Assistant United States Attorney

219 South Dearborn Street

Chicago, IL 60604

11 (312) 353-4220

12 david.decelles@usdoj.gov

14 Dated this 17th day of October, 2021.

16 Respectfully Submitted,

Maurice J. Smith

19 Plaintiff, Pro Se

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MAURICE J. SMITH’S RESPONSES

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