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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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Opposition to Motion to Dismiss FCRA Claim Under 15 U.S.C. § 1681b(b)2, 3 (May 27, 2016)
Almost four years ago, Derrick Milbourne and Samantha Churcher first filed this action alleging that the defendant, JRK Residential America, violated the Fair Credit Reporting Act’s specific requirements governing the use of consumer reports for employment purposes. See 15 U.S.C. § 1681b(b). JRK soon filed a motion to dismiss for lack of jurisdiction, which this Court denied. See Dkt. 20. After this Court certified two classes of plaintiffs, JRK filed a summaryjudgment motion on the class claims, which this Court again denied. See Dkt. 68.
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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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