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Advanced Pleadings Search
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Trial Transcript in Abusive Debt Collection Suit (April 16, 2009)
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Exhibits Showing Form Letters and Protocols Between District Attorneys and Check Collector Masquerading as District Attorney (February 3, 2012)
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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 § 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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Class Complaint in Foreclosure With Impermissible Fees and Mortgagee Failure to Provide Mitigation Notices (June 8, 2012)
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Class Complaint Against Debt Collector for Autodialing Cell Phones (January 19, 2011)
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Sample Class Discovery
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Class Discovery to Debt Collector for Autodialing Cell Phones (February 18, 2011)
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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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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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Discovery re TILA, RICO, False Imprisonment, and State Law Claims
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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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Plaintiff's Supplemental Brief (Schweer v. HOVG)
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Plaintiffs' Supplemental Brief (Tepper v. Amos Financial)
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Appellee Brief (Tepper)
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Barbato Amicus Brief ISO Tepper
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Memo and Order (Amodio v. Wilson & Associates)
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