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Motion in Limine to Preclude Reference to Character in FDCPA Debt Buyer Trial (July 18, 2011)

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Motion in Limine to Preclude Relitigation of State Court Decision in FDCPA Debt Buyer Trial (July 18, 2011)

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Motion in Limine to Preclude Introduction of Assignors Business Records in FDCPA Debt Buyer Trial (July 18, 2011)

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Consumers Motion in Limine for Damages Trial After Prevailing on Summary Judgment in FDCPA Suit on Time-Barred Debt (June 18, 2012)

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Model Brief Arguing Robocalls Cause Concrete Harm to a Plaintiff (May 23, 2016)

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Opposition to Motion to Dismiss FCRA Claim Under 15 U.S.C. § 1681b(b)2, 3 (May 27, 2016)

Almost four years ago, Derrick Milbourne and Samantha Churcher first filed this action alleging that the defendant, JRK Residential America, violated the Fair Credit Reporting Act’s specific requirements governing the use of consumer reports for employment purposes. See 15 U.S.C. § 1681b(b). JRK soon filed a motion to dismiss for lack of jurisdiction, which this Court denied. See Dkt. 20. After this Court certified two classes of plaintiffs, JRK filed a summaryjudgment motion on the class claims, which this Court again denied. See Dkt. 68.

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Supplemental Brief in FDCPA Case on Article III Standing in Light of Spokeo (June 3, 2016)

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CFPB Amicus Brief in FDCPA Case on Article III Standing in Light of Spokeo (June 3, 2016)

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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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Declaration of Larry Oxendine re Applicability of FDCPA to Guaranty Agencies

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Consumer’s Notice of a Rule 30(b)(6) Deposition Listing the Topics of Inquiry in TCPA Case

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Interrogatories, Document Requests, & Requests for Admissions to Payday Lender (AL)

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Requests For Admissions, Interrogatories, and Document Requests re Old Credit Card Debt Purchased by Debt Buyer

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Letter to NAF Requesting Participatory Hearing

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Discovery re Use of Rule of 78s

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Discovery re Mobile Home Defects Caused by Installation

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Discovery Requests and Request to Admit in Case with TILA and RESPA Defenses

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Interrogatories and Document Requests, Predatory Mortgage Lending Case

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Subpoena, Deposition Notice, and Document Request to Insurance Company That Issued Lender’s Undisclosed Private Mortgage Insurance

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Opposition to Motion to Dismiss Credit Repair (CROA) Suit as Arbitration and Forum Selection Clauses Unenforceable

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Motion to Dismiss re Old Credit Card Debt Purchased by Debt Buyer

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Motion To Dismiss re Old Credit Card Debt Purchased by Debt Buyer

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Motion to Dismiss Complaint and Strike Request for Attorney Fees

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Reply Memoranda in Motion to Dismiss re Statute of Limitations

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Motion to Dismiss Credit Card Issuer's Claim

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Motion to Dismiss Claim on Credit Card and Strike Affidavit for Correctness

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Motion to Dismiss Amended Complaint re Credit Card Debt

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Motion to Dismiss Amended Complaint for Damages re Credit Card Debt

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Motion to Dismiss re Old Credit Card Debt Purchased by Debt Buyer

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Discovery re Yo-Yo Sale

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Protective Order in Car Litigation

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Memorandum in Support of Adoption of Protective Order in Car Litigation

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Discovery re Auto Sales and Finance Fraud

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Discovery re Undisclosed Sale of Lemon Buy-Back RV

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Discovery re Used Car Fraud

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Discovery re Hidden Finance Charge in Auto Loan

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Attachments to Memorandum Opposing Motion to Dismiss Mortgage Fraud Claims

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Motion to Abate Foreclosure for Failure to Provide Mitigation Services

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Oppositions to Motions to Dismiss re Mortgage Servicer Abuses

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Motion to Dismiss Due to Lack of Standing

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Consumers' Response to Motion to Dismiss by Title Registration Firm Asserting Right to Foreclose

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Consumers' Response to Motion to Dismiss by Bank Asserting Right to Foreclose

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Action Challenging MERS as Plaintiff

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Motion to Dismiss re MERS Standing to Foreclose

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Motion to Dismiss re MERS Standing to Foreclose

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Motion to Dismiss re MERS Standing to Foreclose