EXHIBIT A 

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 1 of 30 PageID #:5
Return Date: No return date scheduled

Hearing Date: 9/8/2020 10:00 AM - 10:00 AM

Courtroom Number: 2405

Location: District 1 Court

Cook County, IL

FILED

5/11/2020 11:40 AM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH04136 (O

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o 9228621

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2120 - Served

2220 - Not Served

2320 - Served By Mail

2420 - Served By Publication 2421 - Served By Publication

Summons - Alias Summons

2121 - Served

2221 - Not Served

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2321 - Served By Mail §

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(08/01/18) CCG 0001A

25 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

lU BETTY ADAMS, SHAKENA ADAMS, KENNETH ANDERSON,

QUAYUANNA BILLS, JENNIFER BORKOWSKI, BARBARA BREWER,

SYLVIA DEMETROULAKOS, PATRICK DUKES, CHARLES EVANS, and

ALEX MATURANI,

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il (Name all parties) 2020CH04136 Case No.

v.

SANTANDER CONSUMER USA, INC,

0 SUMMONS ALIAS SUMMONS

To each Defendant:

YOU ARE SUMMONED and required to file an answer to the complaint in this case, a copy of

which is hereto attached, or otherwise file your appearance and pay the required fee within thirty

(30) days after service of this Summons, not counting the day of service. To file your answer or

appearance you need access to the internet. Please visit wvw.cookcount\'clerkofcourt.org to initiate

this process. Kiosks with internet access are available at all Clerk’s Office locations. Please refer to

the last page of this document for location information.

If you fail to do so, a judgment by default may be entered against you for the relief

requested in the complaint.

To the Officer:

This Summons must be returned by the officer or other person to whom it was given for service,

with endorsement of service and fees, if any, immediately after service. If service cannot be made,

this Summons shall be returned so endorsed. This Summons may not be served later than thirty (30)

days after its date.

'•r

Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.otg

Page t of 3

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 2 of 30 PageID #:6
Summons - Alias Summons (08/01/18) CCG 0001B

E-£iliiig is now mandatory for documents in civil cases with limited exemptions. To e-file, you must first

create an account with an e-filing service provider. Visit http://efile.iBinoiscourts.gov/service-providers.htm

to learn more and to select a service provider. If you need additional help or have trouble e-filing, visit http://

www.iIlinoiscourts.gov/FAQ/gethelp.asp, or talk with your local circuit clerk’s office.

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o 62075 Witness; Atty. No.:

Atty Name;

Att}^ foi: _

Address- North LaSalle Street, 14tli Floor

City. Chicago

State: ^ Zip;

Telephone:

Primary Email:

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Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcoimtyclerkofcourt.org

Page2of 3

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 3 of 30 PageID #:7
CLERK OF THE CIRCUIT COURT OF COOK COUNTY OFFICE LOCATIONS

o Richard J Daley Center o

SOW Washington

Chicago, IL 60602

District 2 - Skokie

5600 Old Orchard Rd

Skokie, IL 60077

District 3 - Rolling Meadows

2121 EucUd

RoUing Meadows, IL 60008

District 4 - Maywood

1500 Maybrook Ave

Maywood, IL 60153

District 5 - Bridgeview

10220 S 76th Ave

Bridgeview, IL 60455

District 6 - Markham

16501 S Kedzie Pkwy

Markham, IL 60428

Domestic Violence Court

555 W Harrison

Chicago, IL 60607

Juvenile Center Building

2245 W Ogden Ave, Rm 13

Chicago, IL 60602

Criminal Court Building

2650 S California Ave, Rm 526 

Chicago, IL 60608

Domestic Relations Division

Richard} Daley Center

50 W Washington, Rm 802 

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Civil Appeals

Richard J Daley Center

SOW Washington, Rm 801

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Criminal Department

Richard J Daley Center

50 W Washington, Rm 1006 

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

County Division

Richard} Daley Center

50 W Washington, Rm 1202 

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Probate Division

Richard} Daley Center

50 W Washington, Rm 1202 

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Law Division

Richard} Daley Center

50 W Washington, Rm 801

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Traffic Division

Richard } Daley Center

50 W Washington, Lower Level

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

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Richard} Daley Center

50 W Washington, Rm 601

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Chancery Division

Richard} Daley Center

50 W Washington, Rm 802 

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

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Dorothy Brown, Clerk of the Circuit Court of Cook County, IlUnois

cookcountyclerkofcourt.org

Page 3 of 3

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 4 of 30 PageID #:8
12-Person Jury Return Date; No return date scheduled

. Hearing Date: 9/8/2020 10:00 AM - 10:00 AM

Courtroom Number: 2405

Location: District 1 Court

Cook County, IL

FILED

5/8/2020 5:30 PM

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS DOROTHY BROWN

COUNTY DEPARTMENT, CHANCERY DIVISION CIRCUIT CLERK

COOK COUNTY, IL

2020CH04136 BETTY ADAMS, SHAKENA ADAMS,

KENNETH ANDERSON, QUAYUANNA

BILLS, JENNIFER BORKOWSKI,

BARBARA BREWER, SYLVIA

DEMETROULAKOS, PATRICK DUKES,

CHARLES EVANS, and ALEX MATURANI,

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Case No. I

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2020CH04136

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SANTANDER CONSUMER USA, INC., an

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Defendant.

PLAINTIFFS’ COMPLAINT AND DEMAND FOR JURY TRIAL

PlaintiffBetty Adams, Plaintiff Shakena Adams, PlaintiffKenneth Anderson, Plaintiff

Quayuanna Bills, PlaintiffJennifer Borkowski, PlaintiffBarbara Brewer, Plaintiff Sylvia

Demetroulakos, PlaintiffPatrick Dukes, PlaintiffCharles Evans, and PlaintiffAlex Maturani

(“Plaintiffs”) bring this Complaint and Demand for Jury Trial against Defendant Santander

Consumer USA, Inc. (“Defendant” or “Santander”), to stop Defendant’s practice ofmaking

unsolicited telephone calls to Plaintiffs and their family members and charging Plaintiffs

unlawful debt collection fees, and to obtain redress for injuries suffered as a result ofits conduct.

Plaintiffs allege as follows upon personal knowledge as to themselves and their own acts and

experiences, and, as to all other matters, upon information and belief, including investigation

conducted by their attorneys:

NATURE OF THE CASE

1. Defendant Santander Consumer USA, Inc. is a debt collector that has made

repeated and unsolicited telephone calls to Plaintiffs’ cellular phones in an attempt to collect

1

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 5 of 30 PageID #:9
alleged debts in violation ofthe Telephone Consumer Protection Act (47 U.S.C. § 227, et seq.)

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2. Specifically, Santander is an industry leader in collecting on subprime auto loans s

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is portfolio consists ofsubprime receivables from consumers who do not qualify for conventional 25

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that Santander targets and attempts to collect from, whether it or a third party owns the debt, are

often in unstable circumstances where they are relatively more susceptible to harassment.

oppression, and abuse.

3. Unfortunately, Santander capitalizes on these circumstances by incessantly calling

consumers, like Plaintiffs and their loved ones, multiple times a day and routinely charging them

unauthorized fees—like late fees and loan payment fees—that were not contemplated by their

loan agreements.

4. The TCPA was enacted to protect consumers from unsolicited phone calls exactly

like those alleged in this case. Defendant placed thousands ofphone calls—using an automatic

telephone dialing system or an artificial or prerecorded voice—to Plaintiffs’ cellular telephones

without obtaining their prior express consent to be called at those numbers, and despite Plaintiffs’

repeated requests that Defendant stop calling them on their cell phones.

5. By making these debt collection calls. Defendant has caused actual harm in that

Plaintiffs were subjected to the aggravation and nuisance that necessarily accompanies repeated

2

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 6 of 30 PageID #:10
and unsolicited phone calls. In addition, Plaintiffs suffered direct and indirect harm in the form of

monies paid for the receipt ofsuch calls from Defendant. <o

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collection practicesjust like Plaintiffs were subjected to. Specifically, it prohibits debt collectors

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like Santander from, among other things, repeatedly calling Plaintiffs with the intent to annoy.

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U. expressly authorized by the agreement creating the debt or permitted by law. Defendant routinely

and willfully violated each Plaintiffs rights under the FDCPA.

7. In response to Defendant’s unlawful conduct. Plaintiffs now bring the instant

lawsuit seeking to recover statutory damages under the TCPA—trebled due to the knowledge and

willfulness ofDefendant’s conduct—and an injunction requiring Defendant to cease all

unsolicited phone call activities. Plaintiffs also seek an injunction requiring Defendant to cease

imposing unlawful fees on consumers, as well as an award of actual and statutory damages to

Plaintiffs as provided under the FDCPA, together with costs and reasonable attorneys’ fees.

PARTIES

8. PlaintiffBetty Adams is a natural person and citizen ofthe State ofTexas.

9. Plaintiff Shakena Adams is a natural person and citizen ofthe State ofNevada.

10. PlaintiffKenneth Anderson is a natural person and citizen ofthe State ofIllinois.

11. PlaintiffQuayuanna Bills is a natural person and citizen ofthe State ofTennessee.

12. PlaintiffJennifer Borkowski is a natural person and citizen ofthe State ofIllinois.

13. PlaintiffBarbara Brewer is a natural person and citizen ofthe State ofTexas.

14. Plaintiff Sylvia Demetroulakos is a natural person and citizen ofthe State of

3

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 7 of 30 PageID #:11
Florida.

15. PlaintiffPatrick Dukes is a natural person and citizen ofthe State ofTexas.

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17. Plaintiff Alex Maturani is a natural person and citizen ofthe State ofArizona.

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existing under the laws ofthe State ofIllinois with its principal place of business located at 1601

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JURISDICTION AND VENUE

19. The Court has personal jurisdiction over this action pursuant to 735 ILCS 5/2-

209(a)-(b) because Defendant is a corporation organized under the laws ofthe State ofIllinois

and conducts business transactions in this State.

20. Venue is proper under 735 ILCS 5/2-101 and 5/2-102 because Defendant is

incorporated under the laws ofthis State and conducts business in, and therefore resides in. Cook

County.

COMMON FACTUAL ALLEGATIONS

21. Santander services and attempts to collect on billions of dollars in subprime

consumer loans each year. Among other things, Santander creates and sends monthly statements

to consumers, collects loan payments, and processes loan payments. In addition to servicing

loans that it owns, it regularly services and attempts to collect on loans originated and/or owned

by other companies.

22. Many ofSantander’s “customers” are involuntary consumers who are only forced

to work with Santander because it acquired the rights to collect on their loans without their prior

4

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 8 of 30 PageID #:12
knowledge or consent or because their car dealerships independently elected to use Santander to

CD provide subprime financing. These consumers, whose voluntary relationships with car CO

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to keep their vehicles, they must deal with Santander for as long as it services their loans. 5

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regardless ofhow they are treated by it or its employees. in

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despite the fact that they never provided Defendant consent to be called on their cellular

telephones and repeatedly requested that Defendant stop calling them at those numbers.

24. In fact, many ofthe cell phone numbers called were never provided to Defendant

or any other entity for any purpose related to a debt. Instead, Defendant acquired those cell

phone numbers—as well as the phone numbers ofPlaintiffs’ family members, friends, and/or

personal references—through various means such as “skip tracing” {i.e., locating an individual’s

phone number by searching through public and private databases) and “number trapping” {i.e..

capturing phone numbers from which debtors and others place incoming calls to Defendant to

inquire about their debts and adding those to its database ofnumbers to be called in the future).

25. The calls each Plaintiffreceived were made using equipment—specifically.

Defendant’s Aspect dialer system—^that had the capacity to store or produce telephone numbers

to be called using a random or sequential number generator, and to dial such numbers. On

information and belief, Santander’s call logs with Plaintiffs state that each alleged call was either

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Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 9 of 30 PageID #:13
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attempted to respond to or interrupt the artificial voice, no human would respond back.

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26. Additionally, Defendant’s calls utilized interactive voice recognition technology.

also known as a predictive dialer, in which calls are placed by a machine, and when a consumer <

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Defendant. This technology, on information and belief, dials several numbers simultaneously and

connects the call to only those who answer first.

27. Plaintiffs never consented to, requested, or otherwise desired or permitted calls

from Defendant for the purpose ofdebt collection or any other purpose.

28. Plaintiffs were each absent class members in the former putative class action

Espejo V. Santander Consumer USA, Inc., Case No. 1:1 l-cv-08987 (N.D. Ill.), which

commenced on December 19, 2011 and asserted TCPA claims against Santander that were

virtually identical to those alleged by Plaintiffs. Plaintiffs’ claims under the TCPA were thus

equitably tolled by the Espejo matter from December 19, 2011 to October 14, 2016 when class

certification was denied. See Am. Pipe & Const. Co. v. Utah, 414 U.S. 538, 554 (1974).

29. Plaintiffs’ TCPA claims, as well as their FDCPA claims, have been further tolled by

6

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 10 of 30 PageID #:14
FACTS SPECIFIC TO BETTY ADAMS AND SHAKENA ADAMS

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originally received financing through auto loan company Drive Financial Services 5

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32. At no time had PlaintiffBetty Adams or Plaintiff Shakena Adams (together, the

“Adams”) ever provided Defendant or any other entity involved in the purchase ofthe vehicle

prior express consent to call them at their cellular phone numbers, and shortly after the calls

started, the Adams repeatedly asked Defendant to stop calling them at their cellular phone

numbers.

33. Defendant, however, was persistent in its efforts, placing hundreds of calls to

PlaintiffBetty Adams’ and Plaintiff Shakena Adams’ cellular phones. At its peak. Defendant

called the Adams’ cellular phones approximately seven times a day. Defendant routinely called

the Adams’ cellular phones multiple times a day.

34. Many ofthe calls made to Plaintiff Shakena Adams were placed at unusual and

inconvenient times, such as after 9:00 p.m.

35. The calls PlaintiffBetty Adams and Plaintiff Shakena Adams received were made

using equipment—specifically. Defendant’s Aspect dialer system—that had the capacity to store

or produce telephone numbers to be called using a random or sequential number generator, and

to dial such numbers. On information and belief, Santander’s call logs with PlaintiffBetty

Adams and PlaintiffShakena Adams indicate that many ofthe alleged calls were either

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Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 11 of 30 PageID #:15
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which indicate Defendant’s use of an automated telephone dialing system. Moreover, many of

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36. Additionally, Defendant’s calls utilized interactive voice recognition technology.

also known as a predictive dialer, in which calls are placed by a machine, and when a consumer

answers the phone, there is a noticeable pause prior to being connected to a live representative of

Defendant. This technology, on information and belief, dials several numbers simultaneously and

connects the call to only those who answer first.

37. PlaintiffBetty Adams and Plaintiff Shakena Adams never consented to.

requested, or otherwise desired or permitted calls from Defendant for the purpose of debt

collection or for any other purpose. PlaintiffBetty Adams and Plaintiff Shakena Adams

repeatedly insisted that Defendant refrain from calling them on their cellular phones, revoking

any purported consent to be called at those phone numbers.

FACTS SPECIFIC TO KENNETH ANDERSON

38. In July 2006, PlaintiffKenneth Anderson purchased a 2004 Trailblazer LS and

originally received financing through auto loan company HSBC.

39. At some point. Defendant took over PlaintiffAnderson’s auto loan account and

began placing calls to his cellular phone. -0610, attempting to collect on his purported

debt.

8

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 12 of 30 PageID #:16
40. At no time had PlaintiffAnderson ever provided Defendant or any other entity

involved in the purchase ofhis vehicle prior express consent to call him at his cell phone

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his cell phone number.

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phone approximately 10 to 15 times a day. Defendant also placed even more calls to Plaintiff <

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phone and residential landline phone multiple times a day.

42. Many ofthe calls made to PlaintiffAnderson were placed at unusual and

inconvenient times, such as after 9:00 p.m.

43. In its attempts to collect on this purported debt. Defendant even resorted to

repeatedly calling several ofPlaintiffAnderson’s family members without consent.

44. The calls PlaintiffAnderson received were made using equipment—specifically.

Defendant’s Aspect dialer system—that had the capacity to store or produce telephone numbers

to be called using a random or sequential number generator, and to dial such numbers. On

information and belief, Santander’s call logs with PlaintiffAnderson indicate that many ofthe

alleged calls were either

, both ofwhich indicate Defendant’s use of an automated telephone dialing

system. Moreover, many ofthe calls PlaintiffAnderson received used a pre-recorded or robotic9

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 13 of 30 PageID #:17
sounding voice, as opposed to a live Santander agent being on the line.

45. Additionally, Defendant’s calls utilized interactive voice recognition technology.

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permitted calls from Defendant for the purpose ofdebt collection or for any other purpose.

PlaintiffAnderson repeatedly insisted that Defendant refrain from calling him on his cellular

phone, revoking any purported consent to be called at that phone number.

FACTS SPECIFIC TO QUAYUANNA BILLS

47. On May 20, 2008, Plaintiff Quayuanna Bills purchased a 2004 Cadillac CTS and

originally received financing through auto loan company United Auto Acceptance.

48. At some point. Defendant took over PlaintiffBills’ auto loan account and began

placing calls to her cellular phone. -5883, attempting to collect on her purported debt.

49. At no,time had PlaintiffBills ever provided Defendant or any other entity

involved in the purchase of her vehicle prior express consent to call her at her cellular phone

number, and shortly after the calls started, she repeatedly asked Defendant to stop calling her at

her cellular phone number.

Defendant, however, was persistent in its efforts, placing hundreds of calls to

PlaintiffBills’ cellular phone. Defendant routinely called PlaintiffBills’ cellular phone multiple

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times a day.

51. Many ofthe calls made to PlaintiffBills were placed at unusual and inconvenient

10

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 14 of 30 PageID #:18
times, such as before 8:00 a.m.

52. Moreover, Defendant repeatedly called PlaintiffBills at her place of employment.

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information and belief, Santander’s call logs with PlaintiffBills indicate that many ofthe alleged

calls were either

, both ofwhich indicate Defendant’s use of an automated telephone dialing

system. Moreover, many ofthe calls PlaintiffBills received used a pre-recorded or roboticsounding voice, as opposed to a live Santander agent being on the line.

55. Additionally, Defendant’s calls utilized interactive voice recognition technology.

also known as a predictive dialer, in which calls are placed by a machine, and when a consumer

answers the phone, there is a noticeable pause prior to being connected to a live representative of

Defendant. This technology, on information and belief, dials several numbers simultaneously and

connects the call to only those who answer first.

56. PlaintiffBills never consented to, requested, or otherwise desired or permitted

calls from Defendant for the purpose ofdebt collection or for any other purpose. PlaintiffBills

11

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 15 of 30 PageID #:19
repeatedly insisted that Defendant refrain from calling her on her cellular phone, revoking any

purported consent to be called at that phone number.

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involved in the purchase of her vehicle prior express consent to call her at her cellular phone

number, and shortly after the calls started, she repeatedly asked Defendant to stop calling her at

her cellular phone number.

60. Defendant, however, was persistent in its efforts, placing hundreds of calls to

PlaintiffBorkowski’s cellular phone. At its peak. Defendant called PlaintiffBorkowski’s cellular

phone approximately four to five times a day. And on some days. Defendant even called her

cellular phone every hour. Defendant routinely called PlaintiffBorkowski’s cellular phone

multiple times a day.

61. Many ofthe calls made to PlaintiffBorkowski were placed at unusual and

inconvenient times, such as before 8:00 a.m. and after 9:00 p.m.

62. Moreover, Defendant repeatedly called PlaintiffBorkowski at her place of

employment, even after she asked Defendant to stop calling her at work.

63. In its attempts to collect on this purported debt. Defendant even resorted to

repeatedly calling several ofPlaintiffBorkowski’s family members without consent.

64. The calls PlaintiffBorkowski received were made using equipment—specifically.

12

Case: 1:20-cv-03411 Document #: 1-1 Filed: 06/10/20 Page 16 of 30 PageID #:20
Defendant’s Aspect dialer system—that had the capacity to store or produce telephone numbers to

be called using a random or sequential number generator, and to dial such numbers. On information

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Moreover, many ofthe calls PlaintiffBorkowski received left a pre-recorded or robotic-sounding

voicemail, as opposed to a live Santander agent being on the line.

65. Additionally, Defendant’s calls utilized interactive voice recognition technology.

also known as a predictive dialer, in which calls are placed by a machine, and when a consumer

answers the phone, there is a noticeable pause prior to being connected to a live representative of

Defendant. This technology, on information and belief, dials several numbers simultaneously and

connects the call to only those who answer first.

66. Plaintiff Borkowski never consented to, requested, or otherwise desired or

permitted calls from Defendant for the purpose ofdebt collection or for any other purpose. Plaintiff

Borkowski repeatedly insisted that Defendant refrain from calling her on her cellular phone.

revoking any purported consent to be called at that phone number.

FACTS SPECIFIC TO BARBARA BREWER

67. In 2007, Plaintiff Barbara Brewer purchased a 2005 Dodge Ram 1500 and

originally received financing through auto loan company AmeriCredit. PlaintiffBrewer’s loan was

then taken over by HSBC.

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68. At some point, Defendant took over PlaintiffBrewer’s auto loan account and began

placing calls to her cellular phone, -2447, attempting to collect on her purported debt.

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Q 70. Defendant, however, was persistent in its efforts, placing hundreds of calls to

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PlaintiffBrewer’s cellular phone. At its peak. Defendant called PlaintiffBrewer’s cellular phone

approximately six times a day. Defendant routinely called Plaintiff Brewer’s cellular phone

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multiple times a day.

71. Many ofthe calls made to PlaintiffBrewer were placed at unusual and inconvenient

times, such as after 9:00 p.m.

72. In its attempts to collect on this purported debt, Defendant even resorted to

repeatedly calling several ofPlaintiffBrewer’s family members and personal references without

consent.

73. The calls Plaintiff Brewer received were made using equipment—specifically.

Defendant’s Aspect dialer system—^that had the capacity to store or produce telephone numbers to

be called using a random or sequential number generator, and to dial such numbers. On information

and belief, Santander’s call logs with PlaintiffBrewer indicate that many ofthe alleged calls were

either

, both

14

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ofwhich indicate Defendant’s use of an automated telephone dialing system. Moreover, many of

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live Santander agent being on the line.

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74. Additionally, Defendant’s calls utilized interactive voice recognition technology.

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also known as a predictive dialer, in which calls are placed by a machine, and when a consumer

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75. Plaintiff Brewer never consented to, requested, or otherwise desired or permitted

calls from Defendant for the purpose of debt collection or for any other purpose. PlaintiffBrewer

repeatedly insisted that Defendant refrain from calling her on her cellular phone, revoking any

purported consent to be called at that phone number.

FACTS SPECIFIC TO SYLVIA DEMETROULAKOS

76. In November 2010, Plaintiff Sylvia Demetroulakos purchased a 2010 Jeep

Wrangler and received financing from Defendant Santander Consumer USA, Inc.

77. At some point. Defendant began placing calls to Plaintiff Demetroulakos’ cellular

telephone. -0841, attempting to collect on her purported debt.

78. At no time had PlaintiffDemetroulakos ever provided Defendant or any other entity

involved in the purchase of her vehicle prior express consent to call her at her cellular phone

number, and shortly after the calls started, she repeatedly asked Defendant to stop calling her at

her cellular phone number.

79. Defendant, however, was persistent in its efforts, placing hundreds of calls to

Plaintiff Demetroulakos’ cellular phone. At its peak. Defendant called Plaintiff Demetroulakos’

15

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cellular phone approximately three to four times a day. Defendant also placed even more calls to

<D Plaintiff Demetroulakos’ residential landline phone. Defendant routinely called Plaintiff CO

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80. Many of the calls made to Plaintiff Demetroulakos were placed at unusual and 2

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repeatedly calling several ofPlaintiffDemetroulakos’ family members without consent.

83. The calls Plaintiff Demetroulakos received were made using equipmentspecifically. Defendant’s Aspect dialer system—that had the capacity to store or produce telephone

numbers to be called using a random or sequential number generator, and to dial such numbers.

On information and belief, Santander’s call logs with Plaintiff Demetroulakos indicate that many

of the alleged calls were either

, both ofwhich indicate Defendant’s use of an automated telephone

dialing system. Moreover, many ofthe calls PlaintiffDemetroulakos received used a pre-recorded

or robotic-sounding voice, as opposed to a live Santander agent being on the line.

84. Additionally, Defendant’s calls utilized interactive voice recognition technology.

also known as a predictive dialer, in which calls are placed by a machine, and when a consumer

answers the phone, there is a noticeable pause prior to being connected to a live representative of

16

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Defendant. This technology, on information and belief, dials several numbers simultaneously and

connects the call to only those who answer first.

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permitted calls from Defendant forthe purpose ofdebt collection or for any other purpose. Plaintiff

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Demetroulakos repeatedly insisted that Defendant refrain from calling her on her cellular phone. lO

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revoking any purported consent to be called at that phone number. ft

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1500 and originally received financing through auto loan company CitiFinancial.

87. At some point. Defendant took over PlaintiffDukes’ auto loan account and began

placing calls to his cellular phone. -0254, attempting to collect on his purported debt.

88. At no time had Plaintiff Dukes ever provided Defendant or any other entity

involved in the purchase of his vehicle prior express consent to call him at his cellular phone

number, and shortly after the calls started, he repeatedly asked Defendant to stop calling him at his

cellular phone number.

89. Defendant, however, was persistent in its efforts, placing hundreds of calls to

Plaintiff Dukes’ cellular phone. At its peak. Defendant called Plaintiff Dukes’ cellular phone

approximately three or four times a day. Defendant routinely called PlaintiffDukes’ cellular phone

multiple times a day.

90. Many ofthe calls made to PlaintiffDukes were placed at unusual and inconvenient

times, such as before 8:00 a.m. and after 9:00 p.m.

91. Moreover, Defendant repeatedly called PlaintiffDukes at his place ofemployment.

even after he asked Defendant to stop calling him at work.

17

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92. In its attempts to collect on this purported debt, Defendant even resorted to

repeatedly calling several ofPlaintiffDukes’ family members and without consent. (O

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be called using a random or sequential number generator, and to dial such numbers. On information

§ and belief, Santander’s call logs with Plaintiff Dukes indicate that many ofthe alleged calls were

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ofwhich indicate Defendant’s use of an automated telephone dialing system. Moreover, many of

the calls Plaintiff Dukes received used a pre-recorded or robotic-sounding voice, as opposed to a

live Santander agent being on the line.

Additionally, Defendant’s calls utilized interactive voice recognition technology,

also known as a predictive dialer, in which calls are placed by a machine, and when a consumer

answers the phone, there is a noticeable pause prior to being connected to a live representative of

Defendant. This technology, on information and belief, dials several numbers simultaneously and

connects the call to only those who answer first.

94.

Plaintiff Dukes never consented to, requested, or otherwise desired or permitted

calls from Defendant for the purpose of debt collection or for any other purpose. PlaintiffDukes

repeatedly insisted that Defendant refrain from calling him on his cellular phone, revoking any

purported consent to be called at that phone number.

95.

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FACTS SPECIFIC TO CHARLES EVANS

96. On April 8, 2008, Plaintiff Charles Evans purchased a 2006 Chrysler 300 and

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o originally received financing through auto loan company Drive Financial Services.

97. At some point. Defendant took over PlaintiffEvans’ auto loan account and began

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^placing calls to his cellular phone. -802, attempting to collect on his purported debt.

i5 98. At no time had PlaintiffEvans ever provided Defendant or any other entity involved 5)

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Iin the purchase of his vehicle prior express consent to call him at his cellular phone number, and

shortly after the calls started, he repeatedly asked Defendant to stop calling him at his cellular

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phone number.

Defendant, however, was persistent in its efforts, placing hundreds of calls to

Plaintiff Evans’ cellular phone. At its peak. Defendant called Plaintiff Evans’ cellular phone

approximately eight to ten times a day. Defendant routinely called PlaintiffEvans’ cellular phone

multiple times a day.

99.

100. Many ofthe calls made to PlaintiffEvans were placed at unusual and inconvenient

times, such as before 8:00 a.m.

101. In its attempts to collect on this purported debt. Defendant even resorted to

repeatedly calling several ofPlaintiffEvans’ family members without consent.

102. The calls Plaintiff Evans received were made using equipment—specifically.

Defendant’s Aspect dialer system—that had the capacity to store or produce telephone numbers to

be called using a random orsequential number generator, and to dial such numbers. On information

and belief, Santander’s call logs with PlaintiffEvans indicate that many ofthe alleged calls were

either

19

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L both

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104. Plaintiff Evans never consented to, requested, or otherwise desired or permitted

calls from Defendant for the purpose of debt collection or for any other purpose. Plaintiff Evans

repeatedly insisted that Defendant refrain from calling him on his cellular phone, revoking any

purported consent to be called at that phone number.

FACTS SPECIFIC TO ALEX MATURANI

105. On January 30, 2007 Plaintiff Alex Maturani purchased a 2005 Saturn Red Line

and received financing from Defendant Santander Consumer USA, Inc.

106. At some point, Defendant began placing calls to Plaintiff Maturani’s cellular

telephone. -3993, attempting to collect on his purported debt.

107. At no time had Plaintiff Maturani ever provided Defendant or any other entity

involved in the purchase of his vehicle prior express consent to call him at his cellular phone

number, and shortly after the calls started, he repeatedly asked Defendant to stop calling him at his

cellular phone number.

108. Defendant, however, was persistent in its efforts, placing dozens ofcalls to Plaintiff

Maturani’s cellular phone. Defendant also placed even more calls to Plaintiff Maturani’s

20

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residential landline phone. Defendant routinely called Plaintiff Maturani’s cellular phone and

residential landline phone multiple times a day. (O

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inconvenient times, such as before 8:00 a.m.

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Moreover, Defendant repeatedly called Plaintiff Maturani at his place of

employment, even after he asked Defendant to stop calling him at work.

The calls Plaintiff Maturani received were made using equipment—specifically.

Defendant’s Aspect dialer system—that had the capacity to store or produce telephone numbers to

be called using a random or sequential number generator, and to dial such numbers. On information

and belief, Santander’s call logs with Plaintiff Maturani indicate that many of the alleged calls

were either

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[, both ofwhich indicate Defendant’s use of an automated telephone dialing system.

Additionally, Defendant’s calls utilized interactive voice recognition technology,

also known as a predictive dialer, in which calls are placed by a machine, and when

answers the phone, there is a noticeable pause prior to being connected to a live representative of

Defendant. This technology, on information and belief, dials several numbers simultaneously and

connects the call to only those who answer first.

PlaintiffMaturani never consented to, requested, or otherwise desired or permitted

calls from Defendant for the purpose ofdebt collection or for any other purpose. PlaintiffMaturani

repeatedly insisted that Defendant refrain from calling him on his cellular phone, revoking any

112.

a consumer

113.

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purported consent to be called at that phone number

COUNTI

Violation ofthe Telephone Consumer Protection Act

47 U.S.C. § 227(b)(1)(A)

(On Behalf ofPlaintiffs as Against Defendant)

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Q. 114. Plaintiffs incorporate by reference the foregoing allegations as if fully set forth

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telephone numbers, subscribed to and primarily used by Plaintiffs, using equipment that had the

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capacity to store or produce telephone numbers to be called using a random or sequential number

generator, and to dial such numbers.

Defendant utilized a predictive dialer—specifically, its Aspect dialer system—^to

place numerous phone calls to Plaintiffs and other individuals simultaneously and without human

intervention. Defendant’s predictive dialer qualifies as an automatic telephone dialing system

because it is equipment, combining software and hardware aspects, that has the capacity to store

116.

or produce numbers and dial those numbers at random, in sequential order, or from a database of

numbers.

117. Many ofthe phone calls Defendant placed to Plaintiffs’ cellular telephones featured

artificial or prerecorded voices.

118. The phone calls were made to Plaintiffs’ wireless telephones without the consent

of Plaintiffs to receive phone calls on their cellular telephones, and in many instances, without

those numbers being provided to Defendant or any other entity in connection with the debt they

purportedly owed.

119. Once Defendant began placing calls to Plaintiffs’ cellular telephones. Plaintiffs

repeatedly asked Defendant to stop calling them on their cellular telephones, revoking any

22

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purported consent (to the extent it ever existed) to be called at those phone numbers.

120. Defendant has, therefore, violated 47 U.S.C. § 227(b)(l)(A)(iii). As a result of

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inter alia, a minimum of$500.00 in damages for each violation ofsuch Act. If)

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Should the Court determine that Defendant’s misconduct was willful and knowing,

the Court may, pursuant to section 227(b)(3)(C), treble the amount of statutory damages

121. §

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COUNT II

Violation ofthe Fair Debt Collection Practices Act

15 U.S.C. %1692, etseq.

fOn Behalf ofPlaintiffs as Against Defendant!

122. Plaintiffs incorporate by reference the foregoing allegations as if fully set forth

herein.

Plaintiffs are natural persons that were obligated or allegedly obligated to debts

incurred for personal, family, and/or household purposes. As such. Plaintiffs are “consumer[s]”

123.

within the meaning of 15 U.S.C. § 1692a(3).

124. Santander regularly acts as a third-party collection agent for debts owed to others,

as a significant portion ofits business is dedicated to third-party debt servicing wherein Santander

services and attempts to collect on debts owed to and owned by other companies. Moreover, the

principal purpose of Santander’s business is the collection ofdebts. As such. Defendant is a “debt

collector” within the meaning of 15 U.S.C. § 1692a(6).

125. Defendant used a predictive dialer and other instrumentalities of interstate

commerce to employ harassing and abusive means to collect or attempt to collect debts from

Plaintiffs. Among other things. Defendant used a predictive dialer to repeatedly and continuously

23

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cause Plaintiffs’ telephones to ring (often numerous times a day) and engage Plaintiffs in telephone

conversations with the intent to annoy, abuse, and harass Plaintiffs. <D

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the FDCPA, 15 U.S.C. §1692d(5), as to all Plaintiffs.

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127. Several ofthe calls placed to PlaintiffShakena Adams, PlaintiffAnderson, Plaintiff

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Bills, Plaintiff Borkowski, Plaintiff Brewer, Plaintiff Demetroulakos, Plaintiff Dukes, Plaintiff in

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Evans, and PlaintiffMaturani were made at unusual and inconvenient times, such as before 8:00 <

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U. a.m. or after 9:00 p.m., without their prior consent to be contacted at such times, in violation ofthe

FDCPA, 15 U.S.C. §1692c(a)(l).

128. Further, Defendant repeatedly contacted Plaintiff Bills, Plaintiff Borkowski,

Plaintiff Demetroulakos, Plaintiff Dukes, and Plaintiff Maturani at their places of employment,

even after they asked Defendant not to call them at work. Defendant, thus, had reason to know

they could not receive such communications at work, but continued to call them anyways, in

violation ofthe FDCPA, 15 U.S.C. §1692c(a)(3).

Defendant also violated the FDCPA, 15 U.S.C. §1692c(b), as to Plaintiff Betty

Adams, Plaintiff Anderson, Plaintiff Bills, Plaintiff Borkowski, Plaintiff Brewer, Plaintiff

Demetroulakos, PlaintiffDukes, and PlaintiffEvans, by communicating with third parties, such as

Plaintiffs’ family members, friends, and personal references, in connection with Plaintiffs’ alleged

debts, without Plaintiffs’ prior consent to call such third-party persons, and for purposes other than

acquiring location information about Plaintiffs.

129.

130. Defendant also violated the FDCPA, 15 U.S.C. §1692f(l), as to Plaintiff Betty

Adams, PlaintiffShakena Adams, PlaintiffAnderson, PlaintiffBills, PlaintiffBorkowski, Plaintiff

Demetroulakos, and PlaintiffDukes, by collecting money from Plaintiffs—including interest, late

24

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fees, convenience fees, processing fees, online or over-the-phone payment fees, and other

miscellaneous fees, charges, and/or expenses—not expressly authorized by contract or permitted

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131. Defendant’s noncompliance with the FDCPA described herein—including but not

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limited to its unsolicited telephone calls, use of obscene, profane, and abusive language, and

c5 unlawful collection ofmonies from Plaintiffs—^was frequent, persistent, and intentional. S5

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Li. suffered actual damages in the form of, inter alia, monies paid to receive unsolicited telephone

calls and monies paid for interest, late fees, convenience fees, processing fees, online or over-thephone payment fees, and/or other expenses unlawfully charged by Defendant.

133. Accordingly, pursuant to 15 U.S.C. § 1692k;, Plaintiffs are each entitled to, inter

alia, actual damages, costs, and attorneys’ fees and expenses, as well as additional statutory

damages ofup to $1,000 each.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray that the Court enterjudgment in their favor and for the

following relief:

A. Declare that Defendant’s conduct as described herein violates the Telephone

Consumer Protection Act (47 U.S.C. § 227, et seq.), and the Fair Debt Collection Practices Act

(15 U.S.C. §1692, etseq.y.

B. Award actual and statutory damages;

C. Award injunctive reliefrequiring Defendant to permanently cease all unsolicited

phone call activities;

D. Award reasonable litigation expenses and attorneys’ fees; and

25

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E. Award such further and other reliefthe Court deems reasonable and just.

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CO DEMAND FOR TRIAL BY JURY

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o Plaintiffs request trial by jury of all claims that can be so tried.

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0. Respectfully submitted,

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BETTY ADAMS, SHAKENA ADAMS,

KENNETH ANDERSON, QUAYUANNA

BILLS, JENNIFER BORKOWSKI, BARBARA

BREWER, SYLVIA DEMETROULAKOS,

PATRICK DUKES, CHARLES EVANS, and

ALEX MATURANI,

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Dated: May 8, 2020 By: /s/ Schuyler R. Ufkes_______

One ofPlaintiffs’ Attorneys

Benjamin H. Richman

brichman@edelson.com

Schuyler R. Ufkes

sufkes@ede1 son.com

Edelson pc

350 North LaSalle, 14th Floor

Chicago, Illinois 60654

Tel: (312) 589-6370

Fax: (312) 589-6378

Firm No.: 62075

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