IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
DICELLO LEVITT & CASEY LLC,
Movants,
v.
OBJECTING MINORITY NOTEHOLDERS
TO THE PROPOSED CONSENT
JUDGMENT BETWEEN THE CONSUMER
FINANCIAL PROTECTION BUREAU
AND THE NATIONAL COLLEGIATE
MASTER STUDENT LOAN TRUST I, THE
NATIONAL COLLEGIATE STUDENT
LOAN TRUST 2003-1, THE NATIONAL
COLLEGIATE STUDENT LOAN TRUST
2004-1, THE NATIONAL COLLEGIATE
STUDENT LOAN TRUST 2004-2, THE
NATIONAL COLLEGIATE STUDENT
LOAN TRUST 2005-1, THE NATIONAL
COLLEGIATE STUDENT LOAN TRUST
2005-2, THE NATIONAL COLLEGIATE
STUDENT LOAN TRUST 2005-3, THE
NATIONAL COLLEGIATE STUDENT
LOAN TRUST 2006-1, THE NATIONAL
COLLEGIATE STUDENT LOAN TRUST
2006-2, THE NATIONAL COLLEGIATE
STUDENT LOAN TRUST 2006-3, THE
NATIONAL COLLEGIATE STUDENT
LOAN TRUST 2006-4, THE NATIONAL
COLLEGIATE STUDENT LOAN TRUST
2007-1, THE NATIONAL COLLEGIATE
STUDENT LOAN TRUST 2007-2, THE
NATIONAL COLLEGIATE STUDENT
LOAN TRUST 2007-3, AND THE
NATIONAL COLLEGIATE STUDENT
LOAN TRUST 2007-4,
Respondents.
No.
DICELLO LEVITT & CASEY LLC’s MOTION
TO QUASH SUBPOENA AND FOR PROTECTIVE ORDER
Case: 1:19-cv-00252 Document #: 2 Filed: 01/11/19 Page 1 of 3 PageID #:3
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DiCello Levitt & Casey LLC (“DLC”), a Chicago-based law firm which previously
represented fifteen Delaware statutory owner-directed trusts called The National Collegiate
Student Loan Trusts1 (“NCSLTs”), was served with a subpoena in connection with a pending
action brought by the Consumer Financial Protection Bureau (“CFPB”) against the NCSLTs in
the District of Delaware (“CFPB Action”2). The subpoena, served by various intervening parties
in the CFPB Action, seeks documents that far exceed the scope allowed by that court’s
previously-entered scheduling order, and also seeks work product and attorney-client
communications. Further, to the extent the intervening parties seek documents that are actually
within the scope of that court’s scheduling order, DLC informed the intervening parties that it
has no responsive documents. For these reasons, as well as the reasons contained in the
accompanying memorandum of law, DLC respectfully requests that the Court issue a protective
order and quash the subpoena.
1 Comprised of The National Collegiate Master Student Loan Trust I, The National
Collegiate Student Loan Trust 2003-1, The National Collegiate Student Loan Trust 2004-1, The
National Collegiate Student Loan Trust 2004-2, The National Collegiate Student Loan Trust
2005-1, The National Collegiate Student Loan Trust 2005-2, The National Collegiate Student
Loan Trust 2005-3, The National Collegiate Student Loan Trust 2006-1, The National Collegiate
Student Loan Trust 2006-2, The National Collegiate Student Loan Trust 2006-3, The National
Collegiate Student Loan Trust 2006-4, The National Collegiate Student Loan Trust 2007-1, The
National Collegiate Student Loan Trust 2007-2, The National Collegiate Student Loan Trust
2007-3, and The National Collegiate Student Loan Trust 2007-4.
2 Consumer Financial Protection Bureau v. The National Collegiate Master Student Loan
Trust, et al., No. 17-cv-01323-GMS (D. Del.).
Case: 1:19-cv-00252 Document #: 2 Filed: 01/11/19 Page 2 of 3 PageID #:4
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Dated: January 11, 2018 Respectfully submitted by:
/s/ Amy E. Keller
Adam J. Levitt
Amy E. Keller
Adam Prom
DICELLO LEVITT & CASEY LLC
Ten North Dearborn Street
Eleventh Floor
Chicago, Illinois 60602
T 312.214.7900
alevitt@dlcfirm.com
akeller@dlcfirm.com
aprom@dlcfirm.com
Counsel for Movant DiCello Levitt & Casey
LLC
Case: 1:19-cv-00252 Document #: 2 Filed: 01/11/19 Page 3 of 3 PageID #:5
