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Amicus Brief Arguing That Debt Buyers Frequently Bring Collection Suits Without Sufficient Evidence to Prevail (October 11, 2011)
Amicus Brief Arguing that Filing Stale, Baseless Claims by Debt Buyers Violates Fundamental Fairness (April 5, 2010)
Appellate Brief re Sufficiency of Email for FDCPA Written Notice Under E-SIGN Act (7th Cir.) (April 25, 2018)
Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (September 21, 2009)
Reply Brief to U.S. Sup. Ct. Arguing that Legal Errors are not Included in the FDCPA Bona Fide Error Defense (December 17, 2009)
Appellate Brief in Abusive Debt Collection Suit (April 1, 2009)
Consumers Brief Asserting a Debt Collector May Not State the FDCPA Only Recognizes Written Consumer Disputes (November 14, 2012)
Consumers Reply Brief Arguing the Debt Collector Fails to Address the Plain Language of FDCPA § 1692g Regarding Verbal Disputes by Consumers (December 19, 2012)
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)
Class Action Complaint Against Check Collection Company Masquerading as District Attorney (September 9, 2013)
Motion to Strike Affirmative Defenses re FDCPA Violations
Form 31: Complaint Seeking Damages for Violation of Automatic Stay and Unfair Trade Practices (September 12, 2015)
Sample Interrogatories, With and Without Reference to Local Rule
General Interview Checklist for Debt Collection Harassment
This nine-page checklist sets out questions for the client in a debt collection harassment case: information about the client, debt and debt contacts, the client’s objectives, questions about debt collection letters and phone contacts, questions about emotional impact and other damages, questions about third-party contacts and other debt collection abuses, and questions about the underlying debt and other debts.
Chronology of Debt Collection Contacts
This is a short form to assist in setting out the chronology of debt collection contacts, where for each contact the form allows recording of the date and time of contact, the collector’s name and company, the names of people contacted, and whether contacted by phone or letter, and what was said.
Fair Debt Collection Act Violations Checklist
This checklist (created before enactment of Regulation F) lists approximately 50 potential FDCPA violations, allowing the attorney to indicate which have been violated.