Advanced Pleadings Search

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

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

Exhibits Showing Form Letters and Protocols Between District Attorneys and Check Collector Masquerading as District Attorney (February 3, 2012)

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)

Class Complaint in Foreclosure With Impermissible Fees and Mortgagee Failure to Provide Mitigation Notices (June 8, 2012)

Class Complaint Against Debt Collector for Autodialing Cell Phones (January 19, 2011)

Sample Class Discovery

Class Discovery to Debt Collector for Autodialing Cell Phones (February 18, 2011)

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

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

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

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

Plaintiff's Supplemental Brief (Schweer v. HOVG)

Plaintiffs' Supplemental Brief (Tepper v. Amos Financial)

Appellee Brief (Tepper)

Barbato Amicus Brief ISO Tepper

Memo and Order (Amodio v. Wilson & Associates)

Second Amended Complaint (Eastman v. NPL Capital)