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Consumers Statement of Material Facts in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)
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Motion to Compel Production of Debt Buyers Purchase Agreement (August 2012)
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Memorandum Supporting Motion to Compel Production of Debt Buyers Purchase Agreement (August 22, 2012)
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Debt Sellers Loan Sales Agreement (April 14, 2010)
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Plaintiffs Second Document Request re Abusive Debt Collection Calls (February, 2009)
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Interrogatories by Servicemember re Unlawful Debt Collection (2008)
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Request for Admissions to Debt Collector Suing Wrong Consumer (May 10, 2011)
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Consumers Memorandum Supporting Relevance of Discovery Requests to Debt Buyer in FCRA Case (January 1, 2009)
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Memorandum Opposing Debt Buyer's Boilerplate Objections to Discovery in FCRA Identity Theft Case (August 31, 2010)
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Consumers Notice of a Site Inspection Pursuant to Rule 34 in FCRA Identity Theft Case (February 7, 2012)
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Motion to Compel Debt Buyers Response to Discovery in FCRA Identity Theft Case (December 14, 2011)
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Clients Certification in Support of Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 13, 2018)
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Reply Brief in Support of Consumers Motion for Summary Judgment in Debt Collection Suit Against the Wrong Consumer (July 26, 2011)
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Memorandum Arguing Malicious Prosecution Claim Against Collection Lawyers (November 21, 2008)
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Memorandum Supporting Summary Judgment for Debt Collectors Callback Messages Left with Third Parties (February 16, 2010)
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Consumers Memorandum in Support of Summary Judgment in FDCPA Suit on Time-Barred Debt (April 16, 2012)
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Summary Judgment Reply Memorandum in FDCPA Suit on Time-Barred Debt (June 8, 2012)
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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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