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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

PARTIES’ STIPULATION TO BRIEFLY EXTEND BRIEFING SCHEDULE ON 

MOTIONS FOR CLASS CERTIFICATION AND SUMMARY JUDGMENT 

Plaintiffs Henry Espejo and Faye Levins (“Plaintiffs”), and Defendant Santander 

Consumer USA, Inc. (“Defendant”), by and through their undersigned counsel and pursuant to 

Federal Rule of Civil Procedure 6(b) and Local Rule 7.1, hereby stipulate and agree, subject to 

the Court’s approval, to extend the current briefing schedule on Plaintiff Levins’s pending 

Motion for Class Certification and Defendant’s Motion for Summary Judgment (the “Motions”) 

such that the replies in support of the motions shall be due on July 11. In support of the instant 

stipulation, the Parties state as follows: 

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WHEREAS, since filing their Motions, the Parties have worked diligently to review and 

analyze each other’s arguments. Notwithstanding, on July 6, 2016, lead counsel for Plaintiffs 

underwent surgery that was not anticipated at the time the previous briefing schedule was 

entered. While Plaintiffs were hopeful that their ability to finalize their reply briefing by the July 

8th deadline would not be affected, they now require a brief extension through the weekend in 

order to finalize and file their reply. Accordingly, Plaintiffs have requested a modest, additional 

extension of the time to file their reply, to which Defendants have agreed; 

WHEREAS, specifically, the Parties have agreed, subject to the Court’s approval, to 

continue the current briefing schedule such that the replies in support of the Motions would be 

filed no later July 11, 2016; 

WHEREAS, the Parties do not anticipate any further changes to the briefing schedule on 

the Motions and the requested continuances would not affect any other dates or deadlines 

currently set in these matters; 

WHEREAS, in light of the foregoing, the Parties believe that good cause exists to grant 

the relief requested herein and it is not sought for any improper purpose, such as delay; and, 

WHEREAS, the Parties have previously requested two extensions of the briefing 

schedule for the Motions. 

NOW THEREFORE, IT IS HEREBY STIPULATED and AGREED that:

1. The replies in support of the Motions shall be filed no later than July 11, 2016. 

IT IS SO STIPULATED.

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Respectfully submitted, 

HENRY ESPEJO and FAYE LEVINS, 

individually and on behalf of all others similarly 

situated, 

Dated: July 8, 2016 By: s/ J. Dominick Larry 

One of Plaintiffs’ Attorneys

Jay Edelson 

jedelson@edelson.com 

Benjamin H. Richman 

brichman@edelson.com 

J. Dominick Larry 

nlarry@edelson.com 

EDELSON PC

350 North LaSalle Street, 13th Floor 

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 

SANTANDER CONSUMER USA, INC., 

Dated: July 8, 2016 By: s/ Henry Pietrkowski 

One of Defendant’s Attorneys

Henry Pietrkowski (Bar No. 6230048) 

hpietrkowski@reedsmith.com 

James A. Rolfes 

jrolfes@reedsmith.com 

REED SMITH LLP 

10 South Wacker Drive 

Chicago, Illinois 60606 

Tel: (312) 207-1000

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Marc A. Lackner (pro hac vice) 

mlackner@mcguirewoods.com 

David S. Reidy (pro hac vice) 

dreidy@mcguirewoods.com 

MCGUIRE WOODS LLP

505 Sansome Street, Suite 700 

San Francisco, California 94111 

Tel: (415) 844-1974

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SIGNATURE ATTESTATION 

 Pursuant to Section IX(C)(2) of the General Order on Electronic Case Filing, I hereby 

attest that the content of this document is acceptable to all persons whose signatures are indicated 

by a conformed signature (s/) within this e-filed document. 

s/ J. Dominick Larry 

CERTIFICATE OF SERVICE 

I hereby certify that on July 8, 2016, I served the above and foregoing by causing a true 

and accurate copy of such paper to be filed and served on all counsel of record via the Court’s 

CM/ECF electronic filing system. 

s/ J. Dominick Larry 

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