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Advanced Pleadings Search
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Deposition of Collection Agency Owner re Debt Collection Invasion of Privacy
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Consent Judgment re Debt Collection Invasion of Privacy
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Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices
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Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices
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Amicus Brief re Courts Must Frequently Sanction Abusive Debt Collection Conduct
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Stipulations of Proposed Settlements
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Deposition of FDCPA Class Representative re Harassment of Identity Theft Victim
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Link to Official Bankruptcy Forms, with Instructions and Committee Notes
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Link to Additional Pleadings from Public Justice
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Supplemental Brief on Standing in Light of Spokeo in Consumer Privacy Case (In re Nickelodeon) (June 3, 2016)
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Supplemental Brief on Standing in Light of Spokeo in Electronic Privacy Case (Matera v. Google) (June 1, 2016)
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Amicus Brief Supporting Claim Under FHA, ADA, and Rehabilitation Act, Hardaway v. D.C. Housing Authority (D.C. Cir. May 20, 2016)
Amicus Brief in Support of Plaintiff-Appellants' Claim Under FHA, ADA, and Rehabilitation Act (May 20, 2016)
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Appellant Reply Brief re Standing, Storm v. Paytime, Inc. (3d Cir. May 31, 2016)
Appellant Reply Brief Opposing Appellee's Brief Alleging Lack of Standing in a Breach of Contract Claim (May 31, 2016)
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Supplemental Brief re Spokeo, Strubel v. Comenity Bank (2d Cir. June 13, 2016)
Plaintiffs Supplemental Brief re Spokeo in Dismissed FCBA Case (June 13, 2016)
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CFPB Amicus Brief Supporting Standing, Strubel v. Comenity Bank (2d Cir. June 13, 2016)
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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Draft Pre-Trial Order in FDCPA Statute of Limitations Trial Against Debt Buyer (December 1, 2010)
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Plaintiffs Contentions of Fact in FDCPA Statute of Limitations Trial Against Debt Buyer (July 18, 2011)
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Pre-Trial Exhibit in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)
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Sample Plaintiffs Request for Voir Dire Questions (2014)
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Jointly Proposed Voir Dire Questions in FDCPA Trial Against Debt Buyer (July 13, 2018)
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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 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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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 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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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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