Motion to Set Aside Stipulation for Judgment Execution Withheld
Motion to Set Aside Default Judgment re Debt Buyer
Official Form 18: Order Granting Student Loan Discharge in Bankruptcy
Jury Instructions in CROA Case
Verdict Form in CROA Case
Cofan v. Paige Complaint re False Certification Discharge
Complaint re Furniture Store's Forced Sale of Credit Insurance
Sample Complaint for TIL Rescission
Sample HOEPA Complaint for TIL Rescission and Damages
Petition re Wrongful Repossession, Electronic Disablement
Sample TIL Complaint for Money Damages
Fair Credit Billing Act Complaint
Cross-Complaint Against Debt Buyer Seeking to Enforce For-Profit School Enrollment Agreement
Complaint and Answer from Private Loan Collection Action (Arrowood Indemnity)
Motion Papers for TRO and Preliminary Injunction Against State Non-Judicial Foreclosure
Sample Federal Court Motion for Temporary Restraining Order with Brief, Supporting Papers, and Order
Sample Fair Credit Billing Act Document Request
Sample TIL Document Request
This is an annotated sample first request for production of documents in a case involving Truth in Lending claims. This request is based on discovery materials prepared by consumer law practitioners in three different cases involving mortgage loans and auto finance.. It is intended to be adaptable for both loans and credit sales. In most cases, a simplified first document request should be served as soon as practicable in the case.
Sample Consumer Leasing Act Document Request
Sample Fair Credit Billing Act Interrogatories
Sample TIL Interrogatories
Sample Consumer Leasing Act Interrogatories
Deposition of Car Manufacturer's Area Manager re Lemon Law
Declaration of DOE Analyst in False Certification Suit (Wilfred)
DOE Memorandum Supporting Motion to Dismiss False Certification Suit (Wilfred)
Plaintiff's Memorandum Opposing DOE Motion to Dismiss False Certification Suit (Wilfred)
Brief in Arbitration re Whether Heavy-Duty Truck Was a Consumer Product
TIL Disclosure Jury Instructions
Sample HOEPA Jury Instructions
General TIL Jury Instructions
TIL Finance Charge Jury Instructions
Assurance of Discontinuance, In the Matter of PayPal, Inc. (N.Y. Att'y Gen. Mar. 2004)
NY AG Assurance of Discontinuance Against Paypal (Mar. 2004)
Judgment re Furniture Store's Forced Sale of Credit Insurance
Order to Dismiss False Certification Case Against DOE (Wilfred)
Arbitrator Requirement Is Unconscionable Re Bias
Sample Consumer Leasing Act Complaint
Class Complaint to Dept. of Education Seeking False Certification Discharge (Wilfred)
Memorandum of Points and Authorities in Opposition to Preliminary Approval of Class Action Settlement
Complaint, Frey v. Upstart Networks (Wis. Cir. Ct. Oct. 17, 2023)
This Wisconsin small claims court complaint brought by a consumer against a party to a rent-a-bank scheme demonstrates another approach to challenge rent-a-bank schemes, even where the bank is considered the true lender. The consumer can assert non-usury claims against the bank's partners. The company "renting" the bank may be liable as someone who arranges or brokers the loan. In Wisconsin the company may have to be licensed and comply with the requirements of the state credit services organization act.