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Advanced Pleadings Search
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Sample Document Requests, With and Without Reference to Local Rule
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Request to Inspect Premises re Harassment of Identity Theft Victim
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Request for Production by Servicemember re Unlawful Debt Collection
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Discovery re Fraudulent Transfer of Real Estate
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Discovery re Collector's Business Assets
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Discovery re Outrageous Debt Collection Practices
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Discovery re Confusing Debt Validation Notice
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Request for Admissions to Collection Attorney re Debt Collection Violations
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Request for Admissions to Debt Buyer re Debt Collection Violations
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Request for Admissions to Debt Buyer re Debt Collection Violations
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Class Complaint in FDCPA Case
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Discovery in FDCPA Class Action
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Combined Rule 23(c) and (e) Notice of Certification and Settlement
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Jury Instructions re Abusive Debt Collection and Repossession
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Summary Judgment Memo and Reply re Excessive Charges and False Threats
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Summary Judgment Memo re FDCPA and State Debt Collection Violations
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Discovery Dispute Letter to Magistrate Judge re Debt Collection Violations
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Summary Judgment Memo re Debt Collection Violations
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Summary Judgment Declarations re Debt Collection Violations
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Declaration of Consumer re Debt Collection Violations
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Notice of Deposition re Debt Collection Violations
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Notice of the Deposition of 30(b)(6) Corporation re Debt Collection Violations
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Deposition of Collection Lawyer re Debt Collection Violations
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Deposition of Legal Assistant re Debt Collection Violations
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Deposition of Head of Collection Firm re Debt Collection Violations
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Request for Admissions to Owner of Collection Law Firm re Debt Collection Violations
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Complaint re Harassment of Identity Theft Victim
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Discovery re Harassment of Identity Theft Victim
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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 Pretrial Order (March 11, 2011)
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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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Memo Opposing Defendants Motion for Discovery Stay in FCRA Identity Theft Case (March 7, 2012)
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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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Tenants Memorandum Opposing the Landlords Motion for Summary Judgment and Reply to the Landlords Memorandum Opposing the Tenants Motion for Summary Judgment in Wrongful Eviction Case (June 6, 2013)
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Opposition to Summary Judgment for Debt Collectors Autodialing Cell Phones (March 12, 2010)
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Motion in Limine to Permit Exhibits in FDCPA Trial Against Debt Buyer (July 18, 2011)
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