Advanced Pleadings Search

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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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Memorandum in Support of Motion to Compel Insurance Information (April 2011)

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Memorandum in Support of Motion to Compel Insurance Information (April 2011)

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Motion to Compel and Exhibits (November 2010)

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Court's Order Govering Sealed Docs Addendum to Protective Order (May 2008)

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Protective Order MDNC (August 2015)

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Stipulated Protective Order (May 2008)

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Sample Requests for Admissions, With and Without Reference to Local Rule

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Complaint Against Attorney for Seizing Exempt Bank Account Funds

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Complaint re Application of FDCPA to Foreclosure of Deed of Trust

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Complaint Alleging Abusive Calls by Debt Collection Employee

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Sample Complaint Against a Payday Lender

This is a sample state court complaint against a check casher and payday lender, alleging state usury and other state credit law violations, federal RICO, Truth in Lending, UDAP, fraud and misrepresentation. The complaint was submitted by three Kentucky legal aid attorneys at the Appalachian Research & Defense Fund.

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Answer and Counterclaim re Failure to Stop Collections After Settlement

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Plaintiffs First Document Request re Abusive Debt Collection Calls

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Draft Pre-Trial Order in FDCPA Statute of Limitations Trial Against Debt Buyer (December 1, 2010)

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Plaintiffs Contentions of Fact in FDCPA Statute of Limitations Trial Against Debt Buyer (July 18, 2011)

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Pre-Trial Exhibit in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

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Sample Plaintiffs Request for Voir Dire Questions (2014)

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Jointly Proposed Voir Dire Questions in FDCPA Trial Against Debt Buyer (July 13, 2018)

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Trial Transcript in Abusive Debt Collection Suit (April 16, 2009)

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Consumers Opposition to CRAs Motion to Strike Experts Report in Case re Mis-Merged Credit File

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Consumers Memorandum Opposing CRAs Motion to Strike Experts Report in Case re Mis-Merged Credit File

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Settlement and Release of Consumers Claims Against a Debt Buyer

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Summary Judgment Memo re Statute of Limitations (2018)

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Motion to Dismiss Beyond SOL Applying IL Borrowing Statute (2018)

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Complaint re TILA, RICO, False Imprisonment, and State Law Claims

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Amended Class Action Complaint (Bodnar v. Bank of America, No. 5:14-cv-03224)

Amended class action complaint regarding debits and overdraft fees. Filed Aug. 26, 2015.

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Order in Case with Multiple Telemarketing Violations

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Verdict Form in TCPA Case

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

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Plaintiff's Notice of Taking Depositions Duces Tecum of Defendants (February 2017)

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Plaintiffs Rule 26(a) Disclosures (March 2018)

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Plaintiffs Rule 26(a) Disclosures (March 2018)

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Brief for Motion to Compel and Exhibits (November 2010)

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Judgment and Order for Injunction Against Auto Lender (Michigan v. Liquidation, LLC)

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Complaint Against For-Profit School for Debt Enforceability and Offset Certification

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Motion and Memo to Compel Discovery re FDCPA

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Appellate Brief Arguing that FDCPA Does Not Require Intentional Conduct

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Appellate Brief re Collecting Illegal Charges and FDCPA Bona Fide Error Defense

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Opposition to Summary Judgment re Offer of Judgment Does Not Moot FDCPA Class Action

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Discovery re Harassment and Unauthorized Practice of Law under FDCPA

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Summary Judgment Memo re Harassment and Unauthorized Practice of Law under FDCPA

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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)

Memorandum in Support of Motion to Compel Insurance Information (April 2011)

Memorandum in Support of Motion to Compel Insurance Information (April 2011)

Motion to Compel and Exhibits (November 2010)

Court's Order Govering Sealed Docs Addendum to Protective Order (May 2008)

Protective Order MDNC (August 2015)

Stipulated Protective Order (May 2008)

Sample Requests for Admissions, With and Without Reference to Local Rule

Complaint Against Attorney for Seizing Exempt Bank Account Funds

Complaint re Application of FDCPA to Foreclosure of Deed of Trust

Complaint Alleging Abusive Calls by Debt Collection Employee

Sample Complaint Against a Payday Lender

Answer and Counterclaim re Failure to Stop Collections After Settlement

Plaintiffs First Document Request re Abusive Debt Collection Calls

Draft Pre-Trial Order in FDCPA Statute of Limitations Trial Against Debt Buyer (December 1, 2010)

Plaintiffs Contentions of Fact in FDCPA Statute of Limitations Trial Against Debt Buyer (July 18, 2011)

Pre-Trial Exhibit in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

Sample Plaintiffs Request for Voir Dire Questions (2014)

Jointly Proposed Voir Dire Questions in FDCPA Trial Against Debt Buyer (July 13, 2018)

Trial Transcript in Abusive Debt Collection Suit (April 16, 2009)

Consumers Opposition to CRAs Motion to Strike Experts Report in Case re Mis-Merged Credit File

Consumers Memorandum Opposing CRAs Motion to Strike Experts Report in Case re Mis-Merged Credit File

Settlement and Release of Consumers Claims Against a Debt Buyer

Summary Judgment Memo re Statute of Limitations (2018)

Motion to Dismiss Beyond SOL Applying IL Borrowing Statute (2018)

Complaint re TILA, RICO, False Imprisonment, and State Law Claims

Amended Class Action Complaint (Bodnar v. Bank of America, No. 5:14-cv-03224)

Order in Case with Multiple Telemarketing Violations

Verdict Form in TCPA Case

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

Plaintiff's Notice of Taking Depositions Duces Tecum of Defendants (February 2017)

Plaintiffs Rule 26(a) Disclosures (March 2018)

Plaintiffs Rule 26(a) Disclosures (March 2018)

Brief for Motion to Compel and Exhibits (November 2010)

Judgment and Order for Injunction Against Auto Lender (Michigan v. Liquidation, LLC)

Complaint Against For-Profit School for Debt Enforceability and Offset Certification

Motion and Memo to Compel Discovery re FDCPA

Appellate Brief Arguing that FDCPA Does Not Require Intentional Conduct

Appellate Brief re Collecting Illegal Charges and FDCPA Bona Fide Error Defense

Opposition to Summary Judgment re Offer of Judgment Does Not Moot FDCPA Class Action

Discovery re Harassment and Unauthorized Practice of Law under FDCPA

Summary Judgment Memo re Harassment and Unauthorized Practice of Law under FDCPA

Motion, Affidavit, and Reply Memo for Attorney Fees re Harassment and Unauthorized Practice of Law under FDCPA