Advanced Pleadings Search

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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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Motion and Memo to Compel Rule 26(a) Disclosures re Collection of Time Barred Debt

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Class Certification Memo re Collection of Time Barred Debt

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Summary Judgment Memo re Collection of Time Barred Debt

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Opposition to Summary Judgment re Collection of Time Barred Debt

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Memo for Attorney Fees re Collection of Time Barred Debt

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Summary Judgment Memo re Seizure of Exempt Funds in Bank Account

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Appellate Brief re Sale of Paid Debt as FDCPA Violation

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Appellate Brief re Rule 68 Offer of Judgment Does Not Moot Class Action

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Motion for Attorney Fees re FDCPA

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Appeal of Denial of Class Certification on Numerosity, Discovery, and Class Definition

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Summary Judgment Memo re Fictitious Collection Agency Name

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Sample Brief in Support of Motion for Partial Summary Judgment

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Sample Motion in Limine, with Memorandum, To Preclude Attacks on Plaintiff's Character

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Sample Motion in Limine re Attorney Fees

Deposition of Debt Buyer's Collection Attorney

Debt Buyer's Purchase Agreement

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Deposition of Collection Lawyer

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Deposition of Collection Lawyer/Owner

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Deposition of Collection Agency Employee re Debt Collection Invasion of Privacy

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Deposition of Collection Agency Owner re Debt Collection Invasion of Privacy

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Deposition of Debt Collection Agency re FDCPA Violations

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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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Trial Transcript in Abusive Debt Collection Suit (April 16, 2009)

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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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Expert Report Regarding Intentionality of FDCPA Violations and Expert Testimony re FDCPA Damages

Expert Qualifications and Response to Attempt to Preclude Testimony on FDCPA Damages

Motion, Memo, and Reply Memo to Compel Discovery Despite Claims of Confidentiality

Class Complaint re Collection of Time Barred Debt

Deposition Notice re Collection of Time Barred Debt

Motion and Memo to Compel Rule 26(a) Disclosures re Collection of Time Barred Debt

Class Certification Memo re Collection of Time Barred Debt

Summary Judgment Memo re Collection of Time Barred Debt

Opposition to Summary Judgment re Collection of Time Barred Debt

Memo for Attorney Fees re Collection of Time Barred Debt

Summary Judgment Memo re Seizure of Exempt Funds in Bank Account

Appellate Brief re Sale of Paid Debt as FDCPA Violation

Appellate Brief re Rule 68 Offer of Judgment Does Not Moot Class Action

Motion for Attorney Fees re FDCPA

Appeal of Denial of Class Certification on Numerosity, Discovery, and Class Definition

Summary Judgment Memo re Fictitious Collection Agency Name

Sample Brief in Support of Motion for Partial Summary Judgment

Sample Motion in Limine, with Memorandum, To Preclude Attacks on Plaintiff's Character

Sample Motion in Limine re Attorney Fees

Deposition of Debt Buyer's Collection Attorney

Debt Buyer's Purchase Agreement

Deposition of Collection Lawyer

Deposition of Collection Lawyer/Owner

Deposition of Collection Agency Employee re Debt Collection Invasion of Privacy

Deposition of Collection Agency Owner re Debt Collection Invasion of Privacy

Deposition of Debt Collection Agency re FDCPA Violations

Consent Judgment re Debt Collection Invasion of Privacy

Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices

Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices

Amicus Brief re Courts Must Frequently Sanction Abusive Debt Collection Conduct

Stipulations of Proposed Settlements

Deposition of FDCPA Class Representative re Harassment of Identity Theft Victim

Link to Official Bankruptcy Forms, with Instructions and Committee Notes

Link to Additional Pleadings from Public Justice

Supplemental Brief on Standing in Light of Spokeo in Consumer Privacy Case (In re Nickelodeon) (June 3, 2016)

Supplemental Brief on Standing in Light of Spokeo in Electronic Privacy Case (Matera v. Google) (June 1, 2016)

Amicus Brief Supporting Claim Under FHA, ADA, and Rehabilitation Act, Hardaway v. D.C. Housing Authority (D.C. Cir. May 20, 2016)

Appellant Reply Brief re Standing, Storm v. Paytime, Inc. (3d Cir. May 31, 2016)

Supplemental Brief re Spokeo, Strubel v. Comenity Bank (2d Cir. June 13, 2016)

CFPB Amicus Brief Supporting Standing, Strubel v. Comenity Bank (2d Cir. June 13, 2016)

Sample Trial Brief (August 23, 2011)

Sample Pretrial Order (March 11, 2011)

Draft Pre-Trial Order in FDCPA Statute of Limitations Trial Against Debt Buyer (December 1, 2010)

Plaintiffs Contentions of Fact in FDCPA Statute of Limitations Trial Against Debt Buyer (July 18, 2011)

Pre-Trial Exhibit in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

Sample Plaintiffs Request for Voir Dire Questions (2014)

Jointly Proposed Voir Dire Questions in FDCPA Trial Against Debt Buyer (July 13, 2018)

Trial Transcript in Abusive Debt Collection Suit (April 16, 2009)

Exhibits Showing Form Letters and Protocols Between District Attorneys and Check Collector Masquerading as District Attorney (February 3, 2012)

Sample Proposed Jury Instructions (January 7, 2011)