Advanced Pleadings Search

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Sample Proposed Jury Instructions (January 7, 2011)

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Sample Verdict Sheet (2014)

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Proposed Jury Instructions in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

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Proposed Verdict Form in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

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Sample Motion, Declaration, Proposed Order, and Memo for FDCPA Attorney Fees (July 21, 2010)

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Memorandum Supporting Award of Lodestar Attorney Fees Under FDCPA (February 9, 2011)

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Brief of Consumer to Enforce Settlement Agreement and Determine Amount of Attorney Fees in Debt Collection Suit Against the Wrong Consumer (July 19, 2012)

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Consumers Brief Arguing that Testimony of Second Debt Buyers Records Custodian Was Inadmissible Hearsay (October 12, 2011)

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Consumers Reply Brief Arguing that Testimony of Second Debt Buyers Records Custodian Was Inadmissible Hearsay (November 28, 2011)

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Amicus Brief Arguing That Debt Buyers Frequently Bring Collection Suits Without Sufficient Evidence to Prevail (October 11, 2011)

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Amicus Brief Arguing that Filing Stale, Baseless Claims by Debt Buyers Violates Fundamental Fairness (April 5, 2010)

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Appellate Brief re Sufficiency of Email for FDCPA Written Notice Under E-SIGN Act (7th Cir.) (April 25, 2018)

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Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (September 21, 2009)

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Reply Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (December 17, 2009)

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Appellate Brief in Abusive Debt Collection Suit (April 1, 2009)

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Consumers Brief Asserting a Debt Collector May Not State the FDCPA Only Recognizes Written Consumer Disputes (November 14, 2012)

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Consumers Reply Brief Arguing the Debt Collector Fails to Address the Plain Language of FDCPA Â§ 1692g Regarding Verbal Disputes by Consumers (December 19, 2012)

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Consumers Letter Supplementing the Consumers Briefs Pursuant to Rule 28(j) of the Federal Rules of Appellate Procedure in Case Regarding Verbal Disputes by Consumers (March 1, 2013)

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Class Action Complaint Against Check Collection Company Masquerading as District Attorney (September 9, 2013)

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Class Action Complaint for Mortgage Servicers Mishandling of Regular and Escrow Payments, a Loan Modification, and Foreclosure Suit (October 14, 2009)

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Motion to Dismiss, Memo, and Reply re Court Should Not Exercise Supplemental Jurisdiction Over Counterclaim for Debt

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Opposition to Motion to Dismiss re Purposeful Contacts Jurisdiction

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Opposition to Motion to Dismiss re Venue of FDCPA Suit

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Affidavit of Consumer re Venue of FDCPA Suit

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Affidavit of Consumer's Attorney's Legal Assistant re Venue of FDCPA Suit

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Proposed Order Denying Motion to Dismiss re Venue of FDCPA Suit

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Opposition to Motion to Dismiss re "Communication" Standard Under FDCPA

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Memorandum Opposing Motion to Dismiss Suit Against Check Collection Company Masquerading as District Attorney (April 16, 2010)

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Consumers Memorandum Opposing Motion to Dismiss Suit Against Check Collector Masquerading as a District Attorney Under Anti-SLAPP Act (May 5, 2010)

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Motion to Strike Affirmative Defenses re FDCPA Violations

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E-Discovery Strategies in Consumer Cases

This is a seven-page document providing practice tips concerning electronic discovery, titled “E-Discovery Strategies In Consumer Cases: Anticipating And Avoiding Issues Relating To Electronically Stored Information” (March 19, 2018) written by Beth Terrell, Terrell Marshall Law Group PLLC, and Cassandra P. Miller, Edelman, Combs, Latturner & Goodwin, LLC.

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Complaint 1692c(a)(2), e, e(2)(A), e(10), f and State Law (March 7, 2017)

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Complaint 1692c, e, f, TCPA and State Law (July 26, 2012)

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Complaint 1692d, d(4), d(5), e, e(2)(A), e(5), e(8), e(10), f, f(1), f(6), State Law and Bankruptcy Claims (2018)

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Complaint 1692e, e(10), g(a)(3), g(a)(4) and State Law (2015)

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Complaint 1692e, e(10), g(a)(5) and State Law (Aug. 30, 2017)

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Complaint 1692e, f, i (Oct. 29, 2015)

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Complaint 1692f(6) (May 23, 2017)

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Complaint Template Unlicensed Debt Collector (2018)

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Class Action Discovery Kimber Type Claim (March 2018)

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Class Action Discovery Kimber Type Claim (March 2018)

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Class Action Interrogatories (March 2018)

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Class Action Request for Production of Documents (March 2018)

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30(b)(6) Deposition Notice (March 2018)

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30(b)(6) Deposition Notice (March 2018)

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Plaintifs 2nd Supplemental FRCP 26(a) Disclosures (June 2015)

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Plaintiffs Amended Notice of Taking Depositions Duces Tecum of Defendant (November 2014)

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CFPB Amicus Brief Supporting Plaintiffs Standing in Dismissed FCBA Case (June 13, 2016)

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Sample Trial Brief (August 23, 2011)

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Sample Proposed Jury Instructions (January 7, 2011)

Sample Verdict Sheet (2014)

Proposed Jury Instructions in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

Proposed Verdict Form in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

Sample Motion, Declaration, Proposed Order, and Memo for FDCPA Attorney Fees (July 21, 2010)

Memorandum Supporting Award of Lodestar Attorney Fees Under FDCPA (February 9, 2011)

Brief of Consumer to Enforce Settlement Agreement and Determine Amount of Attorney Fees in Debt Collection Suit Against the Wrong Consumer (July 19, 2012)

Consumers Brief Arguing that Testimony of Second Debt Buyers Records Custodian Was Inadmissible Hearsay (October 12, 2011)

Consumers Reply Brief Arguing that Testimony of Second Debt Buyers Records Custodian Was Inadmissible Hearsay (November 28, 2011)

Amicus Brief Arguing That Debt Buyers Frequently Bring Collection Suits Without Sufficient Evidence to Prevail (October 11, 2011)

Amicus Brief Arguing that Filing Stale, Baseless Claims by Debt Buyers Violates Fundamental Fairness (April 5, 2010)

Appellate Brief re Sufficiency of Email for FDCPA Written Notice Under E-SIGN Act (7th Cir.) (April 25, 2018)

Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (September 21, 2009)

Reply Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (December 17, 2009)

Appellate Brief in Abusive Debt Collection Suit (April 1, 2009)

Consumers Brief Asserting a Debt Collector May Not State the FDCPA Only Recognizes Written Consumer Disputes (November 14, 2012)

Consumers Reply Brief Arguing the Debt Collector Fails to Address the Plain Language of FDCPA Â§ 1692g Regarding Verbal Disputes by Consumers (December 19, 2012)

Consumers Letter Supplementing the Consumers Briefs Pursuant to Rule 28(j) of the Federal Rules of Appellate Procedure in Case Regarding Verbal Disputes by Consumers (March 1, 2013)

Class Action Complaint Against Check Collection Company Masquerading as District Attorney (September 9, 2013)

Class Action Complaint for Mortgage Servicers Mishandling of Regular and Escrow Payments, a Loan Modification, and Foreclosure Suit (October 14, 2009)

Motion to Dismiss, Memo, and Reply re Court Should Not Exercise Supplemental Jurisdiction Over Counterclaim for Debt

Opposition to Motion to Dismiss re Purposeful Contacts Jurisdiction

Opposition to Motion to Dismiss re Venue of FDCPA Suit

Affidavit of Consumer re Venue of FDCPA Suit

Affidavit of Consumer's Attorney's Legal Assistant re Venue of FDCPA Suit

Proposed Order Denying Motion to Dismiss re Venue of FDCPA Suit

Opposition to Motion to Dismiss re "Communication" Standard Under FDCPA

Memorandum Opposing Motion to Dismiss Suit Against Check Collection Company Masquerading as District Attorney (April 16, 2010)

Consumers Memorandum Opposing Motion to Dismiss Suit Against Check Collector Masquerading as a District Attorney Under Anti-SLAPP Act (May 5, 2010)

Motion to Strike Affirmative Defenses re FDCPA Violations

E-Discovery Strategies in Consumer Cases

Complaint 1692c(a)(2), e, e(2)(A), e(10), f and State Law (March 7, 2017)

Complaint 1692c, e, f, TCPA and State Law (July 26, 2012)

Complaint 1692d, d(4), d(5), e, e(2)(A), e(5), e(8), e(10), f, f(1), f(6), State Law and Bankruptcy Claims (2018)

Complaint 1692e, e(10), g(a)(3), g(a)(4) and State Law (2015)

Complaint 1692e, e(10), g(a)(5) and State Law (Aug. 30, 2017)

Complaint 1692e, f, i (Oct. 29, 2015)

Complaint 1692f(6) (May 23, 2017)

Complaint Template Unlicensed Debt Collector (2018)

Class Action Discovery Kimber Type Claim (March 2018)

Class Action Discovery Kimber Type Claim (March 2018)

Class Action Interrogatories (March 2018)

Class Action Request for Production of Documents (March 2018)

30(b)(6) Deposition Notice (March 2018)

30(b)(6) Deposition Notice (March 2018)

Plaintifs 2nd Supplemental FRCP 26(a) Disclosures (June 2015)

Plaintiffs Amended Notice of Taking Depositions Duces Tecum of Defendant (November 2014)

CFPB Amicus Brief Supporting Plaintiffs Standing in Dismissed FCBA Case (June 13, 2016)

Sample Trial Brief (August 23, 2011)

Sample Pretrial Order (March 11, 2011)