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Settlement and Release of Consumers Claims Against a Debt Buyer

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Summary Judgment Memo re Statute of Limitations (2018)

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Plaintiffs Amended Notice of Taking Depositions Duces Tecum of Defendant (November 2014)

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Plaintiff's Notice of Taking Depositions Duces Tecum of Defendants (February 2017)

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Plaintiffs Rule 26(a) Disclosures (March 2018)

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Plaintiffs Rule 26(a) Disclosures (March 2018)

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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.

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Brief for Motion to Compel and Exhibits (November 2010)

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Motion and Memo to Compel Discovery re FDCPA

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Appellate Brief Arguing that FDCPA Does Not Require Intentional Conduct

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Appellate Brief re Collecting Illegal Charges and FDCPA Bona Fide Error Defense

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Opposition to Summary Judgment re Offer of Judgment Does Not Moot FDCPA Class Action

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Discovery re Harassment and Unauthorized Practice of Law under FDCPA

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Summary Judgment Memo re Harassment and Unauthorized Practice of Law under FDCPA

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Motion, Affidavit, and Reply Memo for Attorney Fees re Harassment and Unauthorized Practice of Law under FDCPA

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Class Complaint re Confusing Debt Validation Notice

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Class Certification Motion and Memo re Confusing Debt Validation Notice

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Opposition to Summary Judgment re Confusing Debt Validation Notice

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Consent Judgment re Debt Collection Invasion of Privacy

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Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices

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Appellate Brief re Petition Clause Does Not Immunize Unfair and Deceptive Debt Collection Litigation Practices

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Amicus Brief re Courts Must Frequently Sanction Abusive Debt Collection Conduct

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Stipulations of Proposed Settlements

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Deposition of FDCPA Class Representative re Harassment of Identity Theft Victim

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Summary Judgment Motion and Memo re Confusing Debt Validation Notice