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Protective Order MDNC (August 2015)
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Stipulated Protective Order (May 2008)
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Sample Requests for Admissions, With and Without Reference to Local Rule
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Complaint Against Attorney for Seizing Exempt Bank Account Funds
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Complaint re Application of FDCPA to Foreclosure of Deed of Trust
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Complaint Alleging Abusive Calls by Debt Collection Employee
Sample Complaint Against a Payday Lender
This is a sample state court complaint against a check casher and payday lender, alleging state usury and other state credit law violations, federal RICO, Truth in Lending, UDAP, fraud and misrepresentation. The complaint was submitted by three Kentucky legal aid attorneys at the Appalachian Research & Defense Fund.
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Answer and Counterclaim re Failure to Stop Collections After Settlement
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Plaintiffs First Document Request re Abusive Debt Collection Calls
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Draft Pre-Trial Order in FDCPA Statute of Limitations Trial Against Debt Buyer (December 1, 2010)
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Plaintiffs Contentions of Fact in FDCPA Statute of Limitations Trial Against Debt Buyer (July 18, 2011)
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Pre-Trial Exhibit in FDCPA Statute of Limitations Trial Against Debt Buyer (July 13, 2018)
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Sample Plaintiffs Request for Voir Dire Questions (2014)
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Jointly Proposed Voir Dire Questions in FDCPA Trial Against Debt Buyer (July 13, 2018)
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Trial Transcript in Abusive Debt Collection Suit (April 16, 2009)
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Consumers Opposition to CRAs Motion to Strike Experts Report in Case re Mis-Merged Credit File
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Consumers Memorandum Opposing CRAs Motion to Strike Experts Report in Case re Mis-Merged Credit File
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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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Motion to Dismiss Beyond SOL Applying IL Borrowing Statute (2018)
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Complaint re TILA, RICO, False Imprisonment, and State Law Claims
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Amended Class Action Complaint (Bodnar v. Bank of America, No. 5:14-cv-03224)
Amended class action complaint regarding debits and overdraft fees. Filed Aug. 26, 2015.
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Order in Case with Multiple Telemarketing Violations
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