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This is one of three complaints illustrating the use of photographs and images inserted directly into a complaint to visually emphasize facts in a used car case.  The complaints were submitted by Matthew Osborne, a consumer attorney in Northglenn, Colorado.  This complaint is before an arbitrator in an action administered by the American Arbitration Association and involves breach of warranty, undisclosed defects, and misrepresentations concerning repairs performed, and replacement parts inserted into, a used car prior to its sale.

This is one of three complaints illustrating the use of photographs and images inserted directly into a complaint to visually emphasize facts in a used car case.  The complaints were submitted by Matthew Osborne, a consumer attorney in Northglenn, Colorado.  This complaint involves undisclosed wreck damage, failure to properly brand the title, and odometer tampering.

This is one of three complaints illustrating the use of photographs and images inserted directly into a complaint to visually emphasize facts in a used car case.  The complaints were submitted by Matthew Osborne, a consumer attorney in Northglenn, Colorado.  This complaint involves undisclosed wreck damage and undisclosed major vehicle repair problems. 

This is the consumers' reply to the defendant's objection to the consumers' request for attorney fees.  The settled case involved a law firm's use of allegedly unfair debt collection practices when it sought to recover its appointed counsel fees from the indigent defendants it was representing in criminal cases.  Among other reasons why the consumers argued for the court to award them significant attorney fees was the novelty of the case.  The consumers raised claims under the Fair Debt Collection Practices Act (FDCPA) and civil rights statutes, and the reply goes i

This is a 2021 first amended complaint in a class action involving land contracts, filed against Vision Property Management in federal court in Michigan. This action arises out of Vision’s discriminatory targeting of Black homebuyers for abusive credit terms in home purchase transactions. Promising these prospective home buyers the American dream of homeownership, Vision ensnared residents in predominantly Black Detroit-area communities in predatory and discriminatory contracts that were structured to fail.

This is a 2017 second amended complaint against Harbour Portfolio in an action involving land contracts, filed on behalf of a number of African-Americans in federal court in Georgia. The action arises out of Harbour Portfolio’s discriminatory targeting of African-American consumers for abusive credit terms in home purchase “contract for deed” transactions, both by intentional targeting and by utilizing practices that have a foreseeable disparate impact on African-American consumers.

This is a 2019 first amended complaint in a class action involving land contracts, filed against Vision Property Management in New Jersey state court. It argues that the contract is an illegal combination of a lease and a rent-to-own sale of real estate, in which the lease is illegal and the rent-to-own transaction is illegal, deceptive, fraudulent, predatory, and unconscionable. The single document into which they are combined is confusing and internally inconsistent.

This is the first amended complaint in a federal action in Michigan alleging misrepresentation of the terms of residential home sales and financing agreements, failure to disclose hidden credit charges, and conducting business in an unfair and deceptive manner. The complaint alleges deceptive promises of homeownership that lured unsuspecting home buyers into predatory and abusive loans that were designed to fail.

This is a consumer’s motion directed to a mortgage servicer asking the court to deem the consumer’s requests for admission admitted. A separate Pleading and Discovery file is a reply to the servicer’s objection, and a proposed order. These documents address frivolous objections commonly raised by corporate defendants including: the document speaks for itself, the facts are public record and may be easily verified by the requestor, and the request seeks admission of a legal theory rather than a fact. Although filed in state court (Maine) it applies the Fed. R. Civ. P.

This is a reply to the servicer’s objection to the consumer’s request to deem the consumer’s admission requests admitted, and also a proposed order. Another Pleading and Discovery file is the consumer’s motion directed to a mortgage servicer asking the court to deem the consumer’s requests for admission admitted.

This is a jury instruction in an FDCPA case that includes 29 separate instructions. Many apply to the FDCPA case, such as nature and element of the claims, violations of the act, least sophisticated standard, bona fide error defense, and actual and statutory damages. Others are of a more general nature, such as the province of the jury, burden of proof, objections, stipulations, duty in deliberating, and verdict forms.

This is an opposition to a motion to dismiss in a case complaining that a debt collector disclosed the consumer’s personal and financial information a letter vendor. The consumers argue that a requirement that financial data be kept confidential does not violate the First Amendment, that the debt collector violated the plain language of 15 U.S.C. s. 1692c(b), and that the debt collector’s statutory construction arguments lack merit.

This is a trial brief in a FDCPA case where the collector threatened foreclosure on the wrong house and tried to collect from the wrong person, the collector had no intent to foreclose, and the collector had no authority to collect the debt. The brief was written by Gregory Reichenbach, a Perrysburg, Ohio attorney, and Edward Icove, a Cleveland, Ohio attorney.

The sole issue on appeal is whether the district court erred in granting summary judgment to Defendant-Appellant AT&T Services, Inc. (AT&T) on the grounds that its automated text message survey system did not constitute an Automatic Telephone Dialing System as defined by the TCPA.

This complaint (the names have redacted to protect identities) was filed in the Federal District Court of Minnesota by Peter F.

These interrogatories (the names have redacted to protect identities) were submitted in a case filed in the Federal District Court of Minnesota by Peter F.

hese document requests (the names have redacted to protect identities) were submitted in a case filed in the Federal District Court of Minnesota by Peter F.

Class action complaint regarding debits and overdraft fees. Filed June 6, 2014.

This is an answer and affirmative defenses in an foreclosure on a reverse mortgage after the death of one spouse, where the remaining spouse demands proof that the plaintiff is the holder of the reverse mortgage, and alleging that the HECM mortgage was consummated without the required HECM counseling, that the foreclosure was initiated with improper loss mitigation or servicing, and that the plaintiff had unclean hands and initiated foreclosure without complying with a condition precedent.

This is a proposed order of dismissal of a lender foreclosure action on a HECM reverse mortgage relating to non-payment of property charges, where the applied for, and was granted, an “AT RISK” extension of the foreclosure deadlines.  The order sets out that the effect of the AT RISK extension is that the lender will not proceed on the foreclosure for one year and the extension continues thereafter so long as, prior to the expiration of the one-year extension, the homeowner certifies that she continues to meet the criteria for the extension.

This is an action in Pennsylvania state court seeking the court clerk to put a residential foreclosure case into deferred status due to the homeowner’s status as an “At Risk” mortgagor under HECM regulations.

This is a 2018 New Jersey state court summary judgment motion seeking to dismiss a judicial foreclosure action concerning a reverse mortgage because HUD had granted an at risk foreclosure extension.  The motion was filed by Legal Services of New Jersey.