Advanced Pleadings Search

docx

Brief, Baroni v. Wells Fargo Bank (9th Cir. Sept. 19, 2016)

docx

Brief, Baroni v. Bank of N.Y. Mellon (C.D. Cal. June 23, 2016)

docx

Request for Documents, U.S. Bank v. McDowell (N.C. Super. Ct. June 19, 2015)

docx

Proposed Voir Dire, Shankle v. Ocwen Loan Servicing (Md. Cir. Ct.)

docx

Answer, Defenses, and Counterclaims, Deutsche Bank v. Guy (Conn. Super. Ct. Apr. 14, 2014)

docx

First Interrogatories and Requests for Production, Perkins v. New Penn Fin. (W. Va. Cir. Ct.)

docx

First Interrogatories to Plaintiff, U.S. Bank v. McDowell (N.C. Super. Ct. June 19, 2015)

docx

Notice of Deposition, Perkins v. New Penn Fin. (W. Va. Cir. Ct. Oct. 6, 2017)

docx

Opposition to Motion to Dismiss, Bosque v. Wells Fargo Bank (D. Mass. Aug. 11, 2010)

pdf

Reply Memo Supporting Motion to Dismiss Complaint, Cave v. Saxon Mortg. Servs. (E.D. Pa. Aug. 30, 2012)

pdf

Memo Supporting Motion to Dismiss Complaint, Wilson v. Bank of Am. (E.D. Pa. June 30, 2014)

docx

Opposition to Motion for Protective Order, Weller v. JPMorgan Chase Bank (N.D. W. Va. Feb. 23, 2017)

pdf

Complaint in Sedda v. Diamond Auto Sales (Colo.)

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.

pdf

Motion In Limine to Exclude Attorney Fees Evidence (CA)

pdf

Individual Complaint Concerning Sim Card Swaps, Terpin v. ATT Mobility

This is a 2020 individual complaint filed in the Central District of California that the mobile phone carrier failed to protect customers personal and financial information and that this resulted in a SIM card swapping scam, so that the scammer gained control of the customers’ phone number and phone account without gaining possession of the customer’s phone.  Claims against ATT included that the agreement and disclaimers were unconscionable and against public policy, deceit by concealment, misrepresentation, negligence, negligent hiring and supervision, breach of contract, and vi

pdf

Class Complaint Concerning Sim Card Swaps, Bayani v. T-Mobile

This is a 2023 class complaint filed in the Western District of Washington that the mobile phone carrier failed to protect customers personal and financial information and that this resulted in a SIM card swapping scam, so that the scammer gained control of the customers’ phone number and phone account without gaining possession of the customer’s phone.  Claims against T-Mobile included negligence, negligent hiring and supervision, UDAP, violations of the Federal Communications Act, and other federal claims.

pdf

Individual Complaint Concerning Sim Card Swaps, Williams v. ATT Mobility

This is a 2019 individual complaint filed in the Eastern District of North Carolina that the mobile phone carrier failed to protect customers personal and financial information and that this resulted in a SIM card swapping scam, so that the scammer gained control of the customers’ phone number and phone account without gaining possession of the customer’s phone.  Claims against ATT included negligence, negligent hiring and supervision, the North Carolina Anti-Hacking statute, UDAP, and violations of the Federal Communications Act and the Computer Fraud and Abuse Act.