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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

HENRY ESPEJO, individually and on behalf 

of all others similarly situated, 

Plaintiff,

v.

SANTANDER CONSUMER USA, INC., an 

Illinois corporation,

Defendant.

______________________________________

Case No.: 1:11-cv-08987

Honorable Charles P. Kocoras

Magistrate Judge Sidney I. Schenkier

FAYE LEVINS, individually and on behalf of 

all others similarly situated, 

Plaintiff,

v.

SANTANDER CONSUMER USA, INC., an 

Illinois corporation,

Defendant.

Case No.: 1:12-cv-09431

Honorable Charles P. Kocoras

Magistrate Judge Sidney I. Schenkier

PLAINTIFF LEVINS’ UNOPPOSED MOTION FOR 

LEAVE TO FILE DOCUMENTS UNDER SEAL

 Plaintiff Faye Levins (“Plaintiff”), individually and on behalf of a class of similarly 

situated individuals, hereby respectfully moves the Court, without opposition from Defendant 

Santander Consumer USA, Inc. (“Defendant”), for an Order granting her leave to file certain 

documents under seal, either in whole or in part, in conjunction with her Motion for Class 

Certification, (dkt. 173). In support of the instant motion, Plaintiff states as follows: 

1. In order to adequately support her Motion for Class Certification, Plaintiff’s 

Memorandum in Support of Motion for Class Certification (the “Memorandum”) and the 

accompanying Declaration of Jay Edelson (the “Edelson Declaration”), will refer to, quote, and 

attach, certain documents designated by Defendant as “Confidential” pursuant to the protective 
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order entered in this case on October 22, 2014, (Espejo dkt. 106), or containing Plaintiff’s 

personally identifiable information, specifically, her telephone number(s). 

2. In particular, the following exhibits containing confidential information are 

attached to the Edelson Declaration: 

 Exhibit A – Excerpts of the Transcript of the Rule 30(b)(6) Deposition of 

Wayne Nightengale, taken in the related Espejo matter on October 22, 2014. 

 Exhibit B – Financing documents relating to Faye Levins’s Drive Financial 

loan, produced by Santander in discovery in this case bearing bates numbers 

SCUSA/B 0035 through SCUSA/B 0074. 

 Exhibit C – Excerpts of the Transcript of the Deposition of Mark Mooney. 

 Exhibit E –Excerpts of a document titled “Santander Consumer USA Inc. 

Fair Debt Collection Practices Act Policy Including State Debt Collection 

Laws, Revision and Publication Date: February 2010,” produced by Santander 

in discovery in the related Espejo action bearing bates numbers SCUSA/E 

8536 through SCUSA/E 8554. 

 Exhibit F – Excerpts of the Transcript of the Deposition of Joseph Burda. 

 Exhibit G –Excerpts of a document titled “Unified Director User Guide,” 

produced by Santander in the related Espejo action bearing bates numbers 

SCUSA/E 0120 through SCUSA/E 0721. 

 Exhibit I – Excerpts of the Transcript of the Rule 30(b)(6) Deposition of 

Mark Nerios. 

 Exhibit J – Activity notes for Plaintiff Faye Levins’s account, produced by 

Santander in this action bearing bates numbers SCUSA/B 00001 through 

SCUSA/B 00034. 

 Exhibit K – Excerpts of a document produced by Santander in the related 

Espejo action bearing bates numbers SCUSA/E 8587 through SCUSA/E 9087. 

 Exhibit L – Excerpts of the Transcript of the Deposition of Faye Levins. 

 Exhibit M – A document produced as part of T-Mobile, Inc.’s Response to 

Santander’s May 20, 2015 subpoena to produce documents.

 Exhibit O – Excerpts of the Transcript of the Deposition of Michele Rodgers. 

3. The Parties agree that these materials contain non-public, business-sensitive, or 
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proprietary information and information Defendant may be obligated to keep confidential 

pursuant to agreements with third parties. Accordingly, Plaintiff seeks to file them entirely under 

seal. 

4. Given that Plaintiff’s Memorandum discusses the contents of Exhibits A, B, C, E, 

F, G, I, J, K, L, M, and O, Plaintiff also seeks to file that document partially under seal. 

5. Pursuant to the Court’s Local Rules, Plaintiff will promptly submit to the Court in 

chambers, in a sealed envelope—bearing the caption of the case, case number, the title of the 

motion to which the submitted confidential information pertains, and the name and telephone 

number of counsel submitting the documents—unredacted copies of the Memorandum and 

Exhibits A, B, C, E, F, G, I, J, K, L, M, and O to the Edelson Declaration. 

6. Prior to filing the instant motion, the Parties conferred (through counsel) 

regarding the relief requested herein, and Plaintiff is authorized to state that Defendant has no 

opposition to the same. 

WHEREFORE, Plaintiff Faye Levins, individually on behalf of a class of similarly 

situated individuals, respectfully requests that the Court enter an Order (i) granting her leave to 

file Exhibits A, B, C, E, F, G, I, J, K, L, M, and O to the Edelson Declaration submitted in 

support of her Motion for Class Certification entirely under seal, (ii) granting her leave to file her 

Memorandum in Support of Motion for Class Certification partially under seal, and (iii) 

providing such other and further relief as the Court deems reasonable and just. 

Respectfully submitted, 

FAYE LEVINS, individually and on behalf of all 

others similarly situated, 

Dated: April 21, 2016 By: s/ J. Dominick Larry 

One of Plaintiff’s Attorneys
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Jay Edelson 

jedelson@edelson.com 

Benjamin H. Richman 

brichman@edelson.com 

J. Dominick Larry 

nlarry@edelson.com 

EDELSON PC

350 North LaSalle Street, Suite 1300 

Chicago, Illinois 60654 

Tel: 312.589.6370 

Fax: 312.589.6378

Rafey S. Balabanian 

rbalabanian@edelson.com 

EDELSON PC

329 Bryant Street, Suite 2C 

San Francisco, California 94107 

Tel: 415.234.5342 

Fax: 415.373.9435 
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CERTIFICATE OF SERVICE

 I hereby certify that on April 21, 2016, I served the above and foregoing by causing a true 

and accurate copy of such paper to be filed and transmitted to all counsel of record via the 

Court’s CM/ECF electronic filing system.

 s/ J. Dominick Larry