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Complaint 1692e, e(10), g(a)(5) and State Law (Aug. 30, 2017)

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Complaint 1692e, f, i (Oct. 29, 2015)

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Complaint 1692f(6) (May 23, 2017)

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Complaint Template Unlicensed Debt Collector (2018)

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Class Action Discovery Kimber Type Claim (March 2018)

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Class Action Discovery Kimber Type Claim (March 2018)

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Class Action Interrogatories (March 2018)

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Class Action Request for Production of Documents (March 2018)

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30(b)(6) Deposition Notice (March 2018)

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30(b)(6) Deposition Notice (March 2018)

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Plaintifs 2nd Supplemental FRCP 26(a) Disclosures (June 2015)

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Plaintiffs Amended Notice of Taking Depositions Duces Tecum of Defendant (November 2014)

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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)

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Stipulated Protective Order (May 2008)

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Sample Requests for Admissions, With and Without Reference to Local Rule

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Complaint Against Attorney for Seizing Exempt Bank Account Funds

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Complaint re Application of FDCPA to Foreclosure of Deed of Trust

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Complaint Alleging Abusive Calls by Debt Collection Employee

Sample Complaint Against a Payday Lender

This is a sample state court complaint against a check casher and payday lender, alleging state usury and other state credit law violations, federal RICO, Truth in Lending, UDAP, fraud and misrepresentation.  The complaint was submitted by three Kentucky legal aid attorneys at the Appalachian Research & Defense Fund. 

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Answer and Counterclaim re Failure to Stop Collections After Settlement

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Plaintiffs First Document Request re Abusive Debt Collection Calls

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Plaintiffs First Set of Interrogatories re Abusive Debt Collection Calls

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

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Sample Document Requests and Interrogatories to Payday Lender

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

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Motion to Dismiss Counterclaim Re Collection Agency Litigation Abuse

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

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Sample Response to Motion to Dismiss in Payday Lending Case

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Motion Supporting Summary Judgment Re Collection Agency Litigation Abuse

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Reply Brief Supporting Summary Judgment Re Collection Agency Litigation Abuse

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Summary Judgment Motion and Memo re False Threats of Foreclosure

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

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Appellate Opening and Reply Brief re Collection Suits in Distant Forums

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Complaint re Reverse Redlining Violation in Land Installment Sales Contracts

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Temporary Restraining Order re Boat Sale Pursuant to Statutory Lien

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Motion In Limine to Exclude Warranty Disclaimer Evidence (CA)

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Notice to Take Deposition of Car Manufacturer re Warranty Repurchase Refusal (CA)

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Document Request for Warranty Repair Records (CA)

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Document Request for Warranty Repurchase Records (CA)

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Interrogatories to Car Dealer re Warranty Repairs (CA)

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Interrogatories to Car Manufacturer re Warranty Repurchase (CA)

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Motion In Limine to Exclude Attorney Fees Evidence (CA)