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Response to Collector's Objection to Motion for Relief from Judgment Execution Withheld

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Motion to Set Aside Stipulation for Judgment Execution Withheld

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Motion to Set Aside Default Judgment re Debt Buyer

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Official Form 18: Order Granting Student Loan Discharge in Bankruptcy

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Jury Instructions in CROA Case

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Verdict Form in CROA Case

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Cofan v. Paige Complaint re False Certification Discharge

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Complaint re Furniture Store's Forced Sale of Credit Insurance

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Sample Complaint for TIL Rescission

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Sample HOEPA Complaint for TIL Rescission and Damages

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Petition re Wrongful Repossession, Electronic Disablement

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Sample TIL Complaint for Money Damages

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Fair Credit Billing Act Complaint

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Cross-Complaint Against Debt Buyer Seeking to Enforce For-Profit School Enrollment Agreement

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Complaint and Answer from Private Loan Collection Action (Arrowood Indemnity)

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Motion Papers for TRO and Preliminary Injunction Against State Non-Judicial Foreclosure

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Sample Federal Court Motion for Temporary Restraining Order with Brief, Supporting Papers, and Order

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Sample Fair Credit Billing Act Document Request

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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.

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Sample Consumer Leasing Act Document Request

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Sample Fair Credit Billing Act Interrogatories

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Sample TIL Interrogatories

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Sample Consumer Leasing Act Interrogatories

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Deposition of Car Manufacturer's Area Manager re Lemon Law

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Declaration of DOE Analyst in False Certification Suit (Wilfred)

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DOE Memorandum Supporting Motion to Dismiss False Certification Suit (Wilfred)

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Plaintiff's Memorandum Opposing DOE Motion to Dismiss False Certification Suit (Wilfred)

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Brief in Arbitration re Whether Heavy-Duty Truck Was a Consumer Product

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TIL Disclosure Jury Instructions

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Sample HOEPA Jury Instructions

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General TIL Jury Instructions

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TIL Finance Charge Jury Instructions

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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)

 

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Judgment re Furniture Store's Forced Sale of Credit Insurance

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Order to Dismiss False Certification Case Against DOE (Wilfred)

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Arbitrator Requirement Is Unconscionable Re Bias

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Sample Consumer Leasing Act Complaint

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Class Complaint to Dept. of Education Seeking False Certification Discharge (Wilfred)

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Memorandum of Points and Authorities in Opposition to Preliminary Approval of Class Action Settlement

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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.

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Form 31 Complaint Seeking Reconnection of Utility Service and Damages

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Form 32 Motion for Modification of Security Deposit for Utility Service

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Form 33 Letter Advising Belatedly-Added Creditor of Meeting of Creditors

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Form 34 Statement Explaining Debtor’s Failure to Provide Tax Return to Trustee or Creditors

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Form 35 Statement That Documents Required to Be Brought to Meeting of Creditors Do Not Exist or Are Not In Debtor’s Possession

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Form 36 Chapter 7 Section 341(a) Meeting Questions

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Form 37 Section 341(a) Questions from United States Trustee Chapter 7 Handbook

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Form 38 Statement of Information Required by 11 U.S.C. § 341

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Form 39 Debtor’s Motion to Redeem Property Pursuant to 11 U.S.C. § 722

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Form 40 Agreement for Redemption of Property