Advanced Pleadings Search

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Deposition Notice of Witness Presenting Debt Collectors Records and Procedures in TCPA Case (2012)

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Basic Interrogatories, Requests for Admissions, and Request for Production of Documents in FDCPA Case (2010)

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Plaintiffs Fourth Discovery Request re Abusive Debt Collection Calls Filed after Removal to Federal Court (September 23, 2009)

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Requests for Admissions and Documents re False Threats of Foreclosure (January 30, 1998)

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Consumers Opposition to Debt Buyer's Motion to Dismiss in Identity Theft FCRA Case (October 7, 2011)

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Opposition to Motion to Dismiss by an Asserted Servicer of One Mortgage in Foreclosure Case (October 10, 2012)

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Opposition to Motion to Dismiss by a Purported Assignee of the Mortgages in Foreclosure Case (October 10, 2012)

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Opposition to Motion to Dismiss by Foreclosure Attorney in Foreclosure Case (October 10, 2012)

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Brief of Consumer in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

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Consumers Statement of Material Facts in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

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Motion to Compel Production of Debt Buyers Purchase Agreement (August 2012)

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Memorandum Supporting Motion to Compel Production of Debt Buyers Purchase Agreement (August 22, 2012)

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Debt Sellers Loan Sales Agreement (April 14, 2010)

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Plaintiffs Second Document Request re Abusive Debt Collection Calls (February, 2009)

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Interrogatories by Servicemember re Unlawful Debt Collection (2008)

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Request for Admissions to Debt Collector Suing Wrong Consumer (May 10, 2011)

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Consumers Memorandum Supporting Relevance of Discovery Requests to Debt Buyer in FCRA Case (January 1, 2009)

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Memorandum Opposing Debt Buyer's Boilerplate Objections to Discovery in FCRA Identity Theft Case (August 31, 2010)

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Consumers Notice of a Site Inspection Pursuant to Rule 34 in FCRA Identity Theft Case (February 7, 2012)

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Motion to Compel Debt Buyers Response to Discovery in FCRA Identity Theft Case (December 14, 2011)

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Clients Certification in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

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Reply Brief in Support of Consumers Motion for Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 26, 2011)

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Memorandum Arguing Malicious Prosecution Claim Against Collection Lawyers (November 21, 2008)

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Memorandum Supporting Summary Judgment for Debt Collectors Callback Messages Left with Third Parties (February 16, 2010)

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Consumers Memorandum in Support of Summary Judgment in FDCPA Suit on Time-Barred Debt (April 16, 2012)

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Summary Judgment Reply Memorandum in FDCPA Suit on Time-Barred Debt (June 8, 2012)

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Memorandum Arguing Against Preemption in Case Against Mortgage Servicer That Ignored Modification Agreement (February 18, 2011)

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Tenants Memorandum in Support of Summary Judgment Asserting a Wrongful Eviction Violated the FDCPA (May 16, 2013)

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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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Motion to Strike Affirmative Defenses re FDCPA Violations

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Form 31: Complaint Seeking Damages for Violation of Automatic Stay and Unfair Trade Practices (September 12, 2015)

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Sample Interrogatories, With and Without Reference to Local Rule

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Complaint in Individual Case Challenging Offset of Social Security Disability Benefits

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Sample Letter Objecting to Defendant's Discovery Responses

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Deposition Notice of Witness Presenting Debt Collectors Records and Procedures in TCPA Case (2012)

Basic Interrogatories, Requests for Admissions, and Request for Production of Documents in FDCPA Case (2010)

Plaintiffs Fourth Discovery Request re Abusive Debt Collection Calls Filed after Removal to Federal Court (September 23, 2009)

Requests for Admissions and Documents re False Threats of Foreclosure (January 30, 1998)

Consumers Opposition to Debt Buyer's Motion to Dismiss in Identity Theft FCRA Case (October 7, 2011)

Opposition to Motion to Dismiss by an Asserted Servicer of One Mortgage in Foreclosure Case (October 10, 2012)

Opposition to Motion to Dismiss by a Purported Assignee of the Mortgages in Foreclosure Case (October 10, 2012)

Opposition to Motion to Dismiss by Foreclosure Attorney in Foreclosure Case (October 10, 2012)

Brief of Consumer in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

Consumers Statement of Material Facts in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

Motion to Compel Production of Debt Buyers Purchase Agreement (August 2012)

Memorandum Supporting Motion to Compel Production of Debt Buyers Purchase Agreement (August 22, 2012)

Debt Sellers Loan Sales Agreement (April 14, 2010)

Plaintiffs Second Document Request re Abusive Debt Collection Calls (February, 2009)

Interrogatories by Servicemember re Unlawful Debt Collection (2008)

Request for Admissions to Debt Collector Suing Wrong Consumer (May 10, 2011)

Consumers Memorandum Supporting Relevance of Discovery Requests to Debt Buyer in FCRA Case (January 1, 2009)

Memorandum Opposing Debt Buyer's Boilerplate Objections to Discovery in FCRA Identity Theft Case (August 31, 2010)

Consumers Notice of a Site Inspection Pursuant to Rule 34 in FCRA Identity Theft Case (February 7, 2012)

Motion to Compel Debt Buyers Response to Discovery in FCRA Identity Theft Case (December 14, 2011)

Clients Certification in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

Reply Brief in Support of Consumers Motion for Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 26, 2011)

Memorandum Arguing Malicious Prosecution Claim Against Collection Lawyers (November 21, 2008)

Memorandum Supporting Summary Judgment for Debt Collectors Callback Messages Left with Third Parties (February 16, 2010)

Consumers Memorandum in Support of Summary Judgment in FDCPA Suit on Time-Barred Debt (April 16, 2012)

Summary Judgment Reply Memorandum in FDCPA Suit on Time-Barred Debt (June 8, 2012)

Memorandum Arguing Against Preemption in Case Against Mortgage Servicer That Ignored Modification Agreement (February 18, 2011)

Tenants Memorandum in Support of Summary Judgment Asserting a Wrongful Eviction Violated the FDCPA (May 16, 2013)

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)

Motion to Strike Affirmative Defenses re FDCPA Violations

Form 31: Complaint Seeking Damages for Violation of Automatic Stay and Unfair Trade Practices (September 12, 2015)

Sample Interrogatories, With and Without Reference to Local Rule

Complaint in Individual Case Challenging Offset of Social Security Disability Benefits

Sample Letter Objecting to Defendant's Discovery Responses

Interrogatories to Landlord