docx
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docx
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Form 174: Statement of Attorney Pursuant to Rule 2019
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Form 178: Chapter 12 Plan
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Form 179: Motion to Avoid Lien or Non-Possessory, Non-Purchase Money Security Interest
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Form 180: Motion to Modify Confirmed Plan
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Memorandum Supporting Approval of Cy Pres
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Order Granting Cy Pres
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Further Order Granting Approval of Cy Pres
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Memorandum Executed for Receipt of Cy Pres Funds
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General Guidelines on Preserving the Evidence in Your Case
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Order Denying Experian's Motion to Vacate Order to Compel Discovery
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Memorandum Order re Discovery from Fannie Mae
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Order Compelling Random Sampling of Credit Reports from Equifax
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Order Compelling Discovery from Equifax
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Stipulated Protective Order for Discovery from Trans Union
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Order Granting Consumer's Motion to Compel Discovery from Experian
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Brief Opposing Cert re Unconscionability: Limit on Punitive Damages (Cavalier) (AL)
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Grounds of Defense and Counterclaims re Credit Card Debt
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Municipal Complaint Alleging Discriminatory Mortgage Lending Practices
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Motion for Summary Judgment Failure to Prosecute and Counterclaim
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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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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)
web
Link to Official Bankruptcy Forms, with Instructions and Committee Notes
web
Link to Additional Pleadings from Public Justice
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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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Motion, Affidavit, and Reply Memo for Attorney Fees re Harassment and Unauthorized Practice of Law under FDCPA
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Class Complaint re Confusing Debt Validation Notice
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Class Certification Motion and Memo re Confusing Debt Validation Notice
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Opposition to Summary Judgment re Confusing Debt Validation Notice
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Summary Judgment Motion and Memo re Confusing Debt Validation Notice
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Summary Judgment Pleadings re Collection from Unobligated Spouse in Distant Forum
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Appellate Brief re Taxation of Costs to Consumer who Lost FDCPA Suit
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Appellate Brief re Prejudgment Garnishment
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Expert Report Regarding Intentionality of FDCPA Violations and Expert Testimony re FDCPA Damages
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Expert Qualifications and Response to Attempt to Preclude Testimony on FDCPA Damages
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Motion, Memo, and Reply Memo to Compel Discovery Despite Claims of Confidentiality
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Class Complaint re Collection of Time Barred Debt
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Deposition Notice re Collection of Time Barred Debt
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