Pleadings and Discovery

Sample discovery requests in a case involving failure to respond to a QWR asking for the identity of the loan holder. Case litigated by Sarah Mancini, Atlanta Legal Aid. 
 

Sample discovery requests in a case involving failure to respond to a QWR asking for the identity of the loan holder. Case litigated by Sarah Mancini, Atlanta Legal Aid. 
 

Sample discovery requests in a case involving failure to respond to a QWR asking for the identity of the loan holder. Case litigated by Sarah Mancini, Atlanta Legal Aid.

This is a sample of a letter typically sent at the beginning of litigation, or pre-litigation, advising the Defendant to preserve all relevant documents and electronic records. This ESI preservation letter is related to Notices of Error sent to the servicer. Letter drafted by Thomas Cox. 

Statement of Interest of the United States in matter alleging that an algorithm-based tenant screening system had a disparate impact in violation of the Fair Housing Act, Massachusetts Consumer Protection Law, and Massachusetts General Laws.

Complaint alleging that an algorithm-based tenant screening system had a disparate impact in violation of the Fair Housing Act, Massachusetts Consumer Protection Law, and Massachusetts General Laws

Subpoena for records from DocuSign regarding an electronically executed contract for solar panels.

This 2024 federal court brief filed in the Southern District of West Virginia on behalf of a class of consumers successfully argued that clicking a website to set up a free Experian account is not sufficient to bind the consumers to an arbitration clause found in the terms of use. See Cox v. ConsumerInfo.com, Inc., 2024 WL 3625859 (S.D. W. Va. Aug.

This is a 2019 individual complaint filed in the Eastern District of North Carolina that the mobile phone carrier failed to protect customers personal and financial information and that this resulted in a SIM card swapping scam, so that the scammer gained control of the customers’ phone number and phone account without gaining possession of the customer’s phone.  Claims against ATT included negligence, negligent hiring and supervision, the North Carolina Anti-Hacking statute, UDAP, and violations of the Federal Communications Act and the Computer Fraud and Abuse Act.

This is a 2020 individual complaint filed in the Central District of California that the mobile phone carrier failed to protect customers personal and financial information and that this resulted in a SIM card swapping scam, so that the scammer gained control of the customers’ phone number and phone account without gaining possession of the customer’s phone.  Claims against ATT included that the agreement and disclaimers were unconscionable and against public policy, deceit by concealment, misrepresentation, negligence, negligent hiring and supervision, breach of contract, and vi