Advanced Pleadings Search
Sample FDCPA Discovery Requests
Sample Deposition
Sample Notice of Deposition
Sample Deposition Preparation (Plaintiff)
Sample Complaint for Damages for Breach of Implied Warranty of Fitness for a Particular Purpose
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Sample Complaint for Damages for Breach of Express Warranty
Alternative Allegations to Establish Revocation of Acceptance
Complaint (Grey v. Central Credit Services, LLC, Case No. 1:18‐cv‐00774)
This action is brought by Plaintiff for actual damages, statutory damages, and civil penalties against the Defendant Central Credit Services, LLC (“Defendant”), for violation of the Fair Debt Collection Practices Act, 15 U.S.C. §§ 1692 et seq. (“FDCPA”) and the North Carolina Collection Agency Act, N.C.Gen.Stat. §§ 58‐70‐1 et seq. (“NCCAA”), which prohibit debt collectors and collection agencies from engaging in abusive, deceptive, and unfair practices.
Interrogatories in Federal Fair Debt Collection Case
Discovery in Bankruptcy Proceeding to Determine Dischargeability of Student Loan
Complaint to Determine Dischargeability of Student Loan
Student Loan, Complaint to Determine Dischargeability
Sample TIL Complaint for Money Damages
Fair Credit Billing Act Complaint
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 Consumer Leasing Act Interrogatories
Notice Letter re Undisclosed Sale of Wreck Car
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.
Basic Interrogatories, Requests for Admissions, and Request for Production of Documents in FDCPA Case (2010)
Sample Proposed Jury Instructions (January 7, 2011)
Complaint Against Dealer for Car's Prior Use
Complaint Against Extended Service Contract Company re Breach of Contract
Complaint for Violation of 42 U.S.C. 1983, Conversion, and Breach of Peace
Complaint Against Credit Union for Financing Used Cars With Preexisting Liens
This is a state court complaint against a credit union for financing used car sales where there were preexisting liens on the vehicles and the dealer never transferred good title to the consumers. The complaint seeks UDAP and warranty of title remedies against the credit union for the dealer's practices where the dealer referred consumers to the credit union, but the required FTC Holder Notice was improperly missing from the loan documents. Related discovery in the case is also available as companion material to this treatise.
Complaint re Auto Sales and Finance Fraud
Answer and Counterclaims re Old Credit Card Debt Purchased by Debt Buyer
Answer re Old Credit Card Debt Purchased by Debt Buyer
Sample Answer
This is a sample answer to a debt buyer's state court collection lawsuit alleging that no proof of a contract, the action is time-barred, the statute of frauds, no proof of ownership of the debt, lack of legal capacity, service of process, usury, and other defenses. Sample document requests, deposition notice, interrogatories, and other pleadings in the same case are also available at this treatise's companion material.