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Affidavit of Consumer re Venue of FDCPA Suit

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Affidavit of Consumer's Attorney's Legal Assistant re Venue of FDCPA Suit

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Proposed Order Denying Motion to Dismiss re Venue of FDCPA Suit

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Opposition to Motion to Dismiss re "Communication" Standard Under FDCPA

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Memorandum Opposing Motion to Dismiss Suit Against Check Collection Company Masquerading as District Attorney (April 16, 2010)

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Consumers Memorandum Opposing Motion to Dismiss Suit Against Check Collector Masquerading as a District Attorney Under Anti-SLAPP Act (May 5, 2010)

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Memo Opposing Defendants Motion for Discovery Stay in FCRA Identity Theft Case (March 7, 2012)

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Exhibits Showing Form Letters and Protocols Between District Attorneys and Check Collector Masquerading as District Attorney (February 3, 2012)

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Sample Proposed Jury Instructions (January 7, 2011)

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Sample Verdict Sheet (2014)

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Proposed Jury Instructions in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)

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Tenants Memorandum Opposing the Landlords Motion for Summary Judgment and Reply to the Landlords Memorandum Opposing the Tenants Motion for Summary Judgment in Wrongful Eviction Case (June 6, 2013)

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Opposition to Summary Judgment for Debt Collectors Autodialing Cell Phones (March 12, 2010)

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Motion in Limine to Permit Exhibits in FDCPA Trial Against Debt Buyer (July 18, 2011)

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Motion in Limine to Preclude Reference to Settlement Negotiations in FDCPA Debt Buyer Trial (July 18, 2011)

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Motion in Limine to Preclude Reference to Character in FDCPA Debt Buyer Trial (July 18, 2011)

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Motion in Limine to Preclude Relitigation of State Court Decision in FDCPA Debt Buyer Trial (July 18, 2011)

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Motion in Limine to Preclude Introduction of Assignors Business Records in FDCPA Debt Buyer Trial (July 18, 2011)

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Consumers Motion in Limine for Damages Trial After Prevailing on Summary Judgment in FDCPA Suit on Time-Barred Debt (June 18, 2012)

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Model Brief Arguing Robocalls Cause Concrete Harm to a Plaintiff (May 23, 2016)

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Supplemental Brief in FDCPA Case on Article III Standing in Light of Spokeo (June 3, 2016)

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CFPB Amicus Brief in FDCPA Case on Article III Standing in Light of Spokeo (June 3, 2016)

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Class Action Complaint for Mortgage Servicers Mishandling of Regular and Escrow Payments, a Loan Modification, and Foreclosure Suit (October 14, 2009)

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Class Complaint in Foreclosure With Impermissible Fees and Mortgagee Failure to Provide Mitigation Notices (June 8, 2012)

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Class Complaint Against Debt Collector for Autodialing Cell Phones (January 19, 2011)