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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 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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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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Motion to Dismiss Beyond SOL Applying IL Borrowing Statute (2018)
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Complaint re TILA, RICO, False Imprisonment, and State Law Claims
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Discovery re TILA, RICO, False Imprisonment, and State Law Claims
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Motion to Dismiss, Memo, and Reply re Court Should Not Exercise Supplemental Jurisdiction Over Counterclaim for Debt
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Opposition to Motion to Dismiss re Purposeful Contacts Jurisdiction
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Opposition to Motion to Dismiss re Venue of FDCPA Suit
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Affidavit of Consumer re Venue of FDCPA Suit
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Affidavit of Consumer's Attorney's Legal Assistant re Venue of FDCPA Suit
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Proposed Order Denying Motion to Dismiss re Venue of FDCPA Suit
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Opposition to Motion to Dismiss re "Communication" Standard Under FDCPA
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Memorandum Opposing Motion to Dismiss Suit Against Check Collection Company Masquerading as District Attorney (April 16, 2010)
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Consumers Memorandum Opposing Motion to Dismiss Suit Against Check Collector Masquerading as a District Attorney Under Anti-SLAPP Act (May 5, 2010)
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Motion to Strike Affirmative Defenses re FDCPA Violations
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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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Class Action Complaint 1692e, e (10), g(a)(3) (June 29, 2012)
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A.G. Complaint Against Credit Counseling Firm
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Complaint re Debt Collection Violations
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Complaint re Fictitious Collection Agency Name
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Complaint re Attorney Who Allowed Collector to Use Attorney's Name
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Sample Complaint re FDCPA Violations
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Sample Complaint with Federal and State Causes of Action
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Complaint by Servicemember re Unlawful Debt Collection
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Complaint re Seizure of Exempt Funds in Bank Account
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Complaint re Fraudulent Transfer of Real Estate
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Complaint re Debt Collection Invasion of Privacy
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