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Memorandum Arguing Against Preemption in Case Against Mortgage Servicer That Ignored Modification Agreement (February 18, 2011)
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Tenants Memorandum in Support of Summary Judgment Asserting a Wrongful Eviction Violated the FDCPA (May 16, 2013)
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Proposed Verdict Form in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)
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Sample Motion, Declaration, Proposed Order, and Memo for FDCPA Attorney Fees (July 21, 2010)
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Memorandum Supporting Award of Lodestar Attorney Fees Under FDCPA (February 9, 2011)
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Brief of Consumer to Enforce Settlement Agreement and Determine Amount of Attorney Fees in Debt Collection Suit Against the Wrong Consumer (July 19, 2012)
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Consumers Brief Arguing that Testimony of Second Debt Buyers Records Custodian Was Inadmissible Hearsay (October 12, 2011)
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Consumers Reply Brief Arguing that Testimony of Second Debt Buyers Records Custodian Was Inadmissible Hearsay (November 28, 2011)
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Amicus Brief Arguing That Debt Buyers Frequently Bring Collection Suits Without Sufficient Evidence to Prevail (October 11, 2011)
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Amicus Brief Arguing that Filing Stale, Baseless Claims by Debt Buyers Violates Fundamental Fairness (April 5, 2010)
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Appellate Brief re Sufficiency of Email for FDCPA Written Notice Under E-SIGN Act (7th Cir.) (April 25, 2018)
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Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (September 21, 2009)
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Reply Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (December 17, 2009)
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Appellate Brief in Abusive Debt Collection Suit (April 1, 2009)
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Consumers Brief Asserting a Debt Collector May Not State the FDCPA Only Recognizes Written Consumer Disputes (November 14, 2012)
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Consumers Reply Brief Arguing the Debt Collector Fails to Address the Plain Language of FDCPA § 1692g Regarding Verbal Disputes by Consumers (December 19, 2012)
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Consumers Letter Supplementing the Consumers Briefs Pursuant to Rule 28(j) of the Federal Rules of Appellate Procedure in Case Regarding Verbal Disputes by Consumers (March 1, 2013)
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Class Action Complaint Against Check Collection Company Masquerading as District Attorney (September 9, 2013)
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Motion to Strike Affirmative Defenses re FDCPA Violations
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Form 31: Complaint Seeking Damages for Violation of Automatic Stay and Unfair Trade Practices (September 12, 2015)
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Sample Interrogatories, With and Without Reference to Local Rule
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Complaint in Individual Case Challenging Offset of Social Security Disability Benefits
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Sample Letter Objecting to Defendant's Discovery Responses
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