pdf
Search
pdf
Summary Judgment Memo re Statute of Limitations (2018)
pdf
Plaintiffs Amended Notice of Taking Depositions Duces Tecum of Defendant (November 2014)
pdf
Plaintiff's Notice of Taking Depositions Duces Tecum of Defendants (February 2017)
docx
Plaintiffs Rule 26(a) Disclosures (March 2018)
pdf
Plaintiffs Rule 26(a) Disclosures (March 2018)
pdf
docx
Template Discovery Plan (March 2018)
This is a discovery plan in a FDCPA case where the consumer attorney lists the various elements to be proved in the case, what evidence is needed to prove that element, whether the consumer attorney has that evidence, and what evidence should be requested of the defendant or where the consumer attorney should seek that the defendant admit to that element.
pdf
Brief for Motion to Compel and Exhibits (November 2010)
doc
pdf
Motion and Memo to Compel Discovery re FDCPA
doc
pdf
Appellate Brief Arguing that FDCPA Does Not Require Intentional Conduct
doc
pdf
Appellate Brief re Collecting Illegal Charges and FDCPA Bona Fide Error Defense
doc
pdf
Opposition to Summary Judgment re Offer of Judgment Does Not Moot FDCPA Class Action
doc
pdf
Discovery re Harassment and Unauthorized Practice of Law under FDCPA
doc
pdf
Summary Judgment Memo re Harassment and Unauthorized Practice of Law under FDCPA
doc
pdf
Motion, Affidavit, and Reply Memo for Attorney Fees re Harassment and Unauthorized Practice of Law under FDCPA
doc
pdf
Class Complaint re Confusing Debt Validation Notice
doc
pdf
Class Certification Motion and Memo re Confusing Debt Validation Notice
doc
pdf
Opposition to Summary Judgment re Confusing Debt Validation Notice
pdf
Consent Judgment re Debt Collection Invasion of Privacy
pdf
Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices
pdf
Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices
pdf
Amicus Brief re Courts Must Frequently Sanction Abusive Debt Collection Conduct
pdf
Stipulations of Proposed Settlements
pdf
Deposition of FDCPA Class Representative re Harassment of Identity Theft Victim
doc
pdf