Advanced Pleadings Search | NCLC Digital Library

doc pdf

Consumers Memorandum Supporting Relevance of Discovery Requests to Debt Buyer in FCRA Case (January 1, 2009)

doc pdf

Memorandum Opposing Debt Buyer's Boilerplate Objections to Discovery in FCRA Identity Theft Case (August 31, 2010)

pdf

Consumers Notice of a Site Inspection Pursuant to Rule 34 in FCRA Identity Theft Case (February 7, 2012)

pdf

Motion to Compel Debt Buyers Response to Discovery in FCRA Identity Theft Case (December 14, 2011)

pdf

Motion for Sanctions Against Stonewalling Debt Buyer in FCRA Identity Theft Case (December 14, 2011)

pdf

Memo Supporting Sanctions Against Stonewalling Debt Buyer in FCRA Identity Theft Case (December 14, 2011)

pdf

Plaintiffs Reply to Memo Supporting Sanctions Against Stonewalling Debt Buyer in FCRA Identity Theft Case (January 9, 2012)

doc pdf

Memo Opposing Defendants Motion for Protective Order in FCRA Identity Theft Case (September 12, 2011)

pdf

Reply Memo Supporting Protective Order and Sanctions Against Debt Buyer in FCRA Identity Theft Case (December 14, 2011)

pdf

Consumers First Memo Supporting Overruling of Defendants Privilege Objections and to Compel Discovery Response in FCRA Identity Theft Case (January 5, 2012)

pdf

Consumers Second Memo Supporting Overruling of Defendants Privilege Objections and to Compel Discovery Response in FCRA Identity Theft Case (March 7, 2012)

docx pdf

Consumers Motion to Compel Debt Collectors Production of Employee Records and Prior Complaints of Abusive Collection Practices (April 8, 2010)

pdf

Consumers Memorandum Supporting Motion to Compel Debt Collectors Production of Employee Records and Prior Complaints of Abusive Collection Practices (April 8, 2010)

docx pdf

Deposition Notice of Witness Presenting Debt Collectors Records and Procedures in FDCPA Case (2011)

docx pdf

Deposition Notice of Witness Presenting Debt Collectors Records and Procedures in TCPA Case (2012)

docx pdf

Basic Interrogatories, Requests for Admissions, and Request for Production of Documents in FDCPA Case (2010)

docx pdf

Plaintiffs Fourth Discovery Request re Abusive Debt Collection Calls Filed after Removal to Federal Court (September 23, 2009)

doc pdf

Requests for Admissions and Documents re False Threats of Foreclosure (January 30, 1998)

pdf

Consumers Opposition to Debt Buyer's Motion to Dismiss in Identity Theft FCRA Case (October 7, 2011)

doc pdf

Opposition to Motion to Dismiss by an Asserted Servicer of One Mortgage in Foreclosure Case (October 10, 2012)

doc pdf

Opposition to Motion to Dismiss by a Purported Assignee of the Mortgages in Foreclosure Case (October 10, 2012)

doc pdf

Opposition to Motion to Dismiss by Foreclosure Attorney in Foreclosure Case (October 10, 2012)

docx pdf

Brief of Consumer in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

docx pdf

Consumers Statement of Material Facts in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

docx pdf

Clients Certification in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

docx pdf

Reply Brief in Support of Consumers Motion for Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 26, 2011)

pdf

Memorandum Arguing Malicious Prosecution Claim Against Collection Lawyers (November 21, 2008)

doc pdf

Memorandum Supporting Summary Judgment for Debt Collectors Callback Messages Left with Third Parties (February 16, 2010)

doc pdf

Consumers Memorandum in Support of Summary Judgment in FDCPA Suit on Time-Barred Debt (April 16, 2012)

doc pdf

Summary Judgment Reply Memorandum in FDCPA Suit on Time-Barred Debt (June 8, 2012)

docx pdf

Memorandum Arguing Against Preemption in Case Against Mortgage Servicer That Ignored Modification Agreement (February 18, 2011)

docx pdf

Tenants Memorandum in Support of Summary Judgment Asserting a Wrongful Eviction Violated the FDCPA (May 16, 2013)

pdf

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)

doc pdf

Opposition to Summary Judgment for Debt Collectors Autodialing Cell Phones (March 12, 2010)

doc pdf

Motion in Limine to Permit Exhibits in FDCPA Trial Against Debt Buyer (July 18, 2011)

pdf

Plaintiffs Third Discovery Request re Abusive Debt Collection Calls Focused on Complaints about the Defendants Debt Collection Activities

pdf

Sample Document Requests and Interrogatories to Payday Lender

pdf

Memorandum Opposing Debt Buyers Boilerplate Objections to Discovery in FCRA Identity Theft Case

docx pdf

Motion to Dismiss Counterclaim Re Collection Agency Litigation Abuse

docx pdf

Reply Brief in Motion to Dismiss Counterclaim Re Collection Agency Litigation Abuse

pdf

Sample Response to Motion to Dismiss in Payday Lending Case

docx pdf

Motion Supporting Summary Judgment Re Collection Agency Litigation Abuse

docx pdf

Reply Brief Supporting Summary Judgment Re Collection Agency Litigation Abuse

doc pdf

Summary Judgment Motion and Memo re False Threats of Foreclosure

docx pdf

Consumer's Proposed Jury and Verdict Form in Debt Collection Suit Against the Wrong Consumer

doc pdf

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

doc pdf

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

doc pdf

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

doc pdf

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

doc pdf

Consumers Memorandum Supporting Relevance of Discovery Requests to Debt Buyer in FCRA Case (January 1, 2009)

Memorandum Opposing Debt Buyer's Boilerplate Objections to Discovery in FCRA Identity Theft Case (August 31, 2010)

Consumers Notice of a Site Inspection Pursuant to Rule 34 in FCRA Identity Theft Case (February 7, 2012)

Motion to Compel Debt Buyers Response to Discovery in FCRA Identity Theft Case (December 14, 2011)

Motion for Sanctions Against Stonewalling Debt Buyer in FCRA Identity Theft Case (December 14, 2011)

Memo Supporting Sanctions Against Stonewalling Debt Buyer in FCRA Identity Theft Case (December 14, 2011)

Plaintiffs Reply to Memo Supporting Sanctions Against Stonewalling Debt Buyer in FCRA Identity Theft Case (January 9, 2012)

Memo Opposing Defendants Motion for Protective Order in FCRA Identity Theft Case (September 12, 2011)

Reply Memo Supporting Protective Order and Sanctions Against Debt Buyer in FCRA Identity Theft Case (December 14, 2011)

Consumers First Memo Supporting Overruling of Defendants Privilege Objections and to Compel Discovery Response in FCRA Identity Theft Case (January 5, 2012)

Consumers Second Memo Supporting Overruling of Defendants Privilege Objections and to Compel Discovery Response in FCRA Identity Theft Case (March 7, 2012)

Consumers Motion to Compel Debt Collectors Production of Employee Records and Prior Complaints of Abusive Collection Practices (April 8, 2010)

Consumers Memorandum Supporting Motion to Compel Debt Collectors Production of Employee Records and Prior Complaints of Abusive Collection Practices (April 8, 2010)

Deposition Notice of Witness Presenting Debt Collectors Records and Procedures in FDCPA Case (2011)

Deposition Notice of Witness Presenting Debt Collectors Records and Procedures in TCPA Case (2012)

Basic Interrogatories, Requests for Admissions, and Request for Production of Documents in FDCPA Case (2010)

Plaintiffs Fourth Discovery Request re Abusive Debt Collection Calls Filed after Removal to Federal Court (September 23, 2009)

Requests for Admissions and Documents re False Threats of Foreclosure (January 30, 1998)

Consumers Opposition to Debt Buyer's Motion to Dismiss in Identity Theft FCRA Case (October 7, 2011)

Opposition to Motion to Dismiss by an Asserted Servicer of One Mortgage in Foreclosure Case (October 10, 2012)

Opposition to Motion to Dismiss by a Purported Assignee of the Mortgages in Foreclosure Case (October 10, 2012)

Opposition to Motion to Dismiss by Foreclosure Attorney in Foreclosure Case (October 10, 2012)

Brief of Consumer in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

Consumers Statement of Material Facts in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

Clients Certification in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)

Reply Brief in Support of Consumers Motion for Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 26, 2011)

Memorandum Arguing Malicious Prosecution Claim Against Collection Lawyers (November 21, 2008)

Memorandum Supporting Summary Judgment for Debt Collectors Callback Messages Left with Third Parties (February 16, 2010)

Consumers Memorandum in Support of Summary Judgment in FDCPA Suit on Time-Barred Debt (April 16, 2012)

Summary Judgment Reply Memorandum in FDCPA Suit on Time-Barred Debt (June 8, 2012)

Memorandum Arguing Against Preemption in Case Against Mortgage Servicer That Ignored Modification Agreement (February 18, 2011)

Tenants Memorandum in Support of Summary Judgment Asserting a Wrongful Eviction Violated the FDCPA (May 16, 2013)

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)

Opposition to Summary Judgment for Debt Collectors Autodialing Cell Phones (March 12, 2010)

Motion in Limine to Permit Exhibits in FDCPA Trial Against Debt Buyer (July 18, 2011)

Plaintiffs Third Discovery Request re Abusive Debt Collection Calls Focused on Complaints about the Defendants Debt Collection Activities

Sample Document Requests and Interrogatories to Payday Lender

Memorandum Opposing Debt Buyers Boilerplate Objections to Discovery in FCRA Identity Theft Case

Motion to Dismiss Counterclaim Re Collection Agency Litigation Abuse

Reply Brief in Motion to Dismiss Counterclaim Re Collection Agency Litigation Abuse

Sample Response to Motion to Dismiss in Payday Lending Case

Motion Supporting Summary Judgment Re Collection Agency Litigation Abuse

Reply Brief Supporting Summary Judgment Re Collection Agency Litigation Abuse

Summary Judgment Motion and Memo re False Threats of Foreclosure

Consumer's Proposed Jury and Verdict Form in Debt Collection Suit Against the Wrong Consumer

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

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

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

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

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