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August 20, 2009 – 6:05 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
JOHN L. DOHERTY, JR. )
)
Plaintiff, )
vs. )
) Civil Action No. 07-3049
TRANS UNION, LLC, ET AL. )
)
Defendants. )
)
PLAINTIFF JOHN L. DOHERTY, JR.’S MEMORANDUM OF LAW IN SUPPORT OF HIS RESPONSE IN OPPOSITION TO DEFENDANT DELL FINANCIAL SERVICES’ MOTION FOR PARTIAL SUMMARY JUDGMENT
Plaintiff John L. Doherty, Jr., through counsel, hereby respectfully submits this Memorandum of Law in opposition to Defendant Dell Financial Services’ (“Dell”) Motion for Partial Summary Judgment (“Motion”) (Docket No. 23). For the reasons below, the Motion should be denied.
Plaintiff is a victim of identity theft at the hands of his estranged brother, William Doherty. Defendant Dell is the company that permitted William Doherty to obtain at least two computers (one on a business credit account and a second on a consumer credit account) in Plaintiff’s name using his good credit. It then proceeded to hold Plaintiff (not William Doherty) ...
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August 20, 2009 – 6:04 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
CHRISTOPHER JUNG )
)
Plaintiff, )
vs. )
) Civil Action No. 07-2514
TRANS UNION, LLC, et al. )
)
Defendants. )
)
PLAINTIFF CHRISTOPHER JUNG’S MEMORANDUM OF LAW
IN SUPPORT OF HIS RESPONSE IN OPPOSITION TO DEFENDANT
TRANS UNION, LLC’S MOTION FOR SUMMARY JUDGMENT
Plaintiff Christopher Jung, through counsel, hereby respectfully submits this Memorandum of Law in opposition to Defendant Trans Union, LLC’s (TU) Motion for Summary Judgment (Motion) (Docket Nos. 53, 54, 55). For the reasons below, the Motion should be denied.
I. INTRODUCTION
Jung brought this consumer action seeking relief under the Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq. (FCRA) and related common law claims against TU, one of the major consumer reporting agencies (CRA) in the world. The parties stipulated to dismiss the common law claims so that they can streamline this matter for trial. (See Docket No. 56) (submitted April 24, 2009). The FCRA claims, therefore, are ...
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August 20, 2009 – 6:02 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LARKAY D. WESLEY )
on behalf of herself and all others )
similarly situated )
) C.A. No. 05-3523
Plaintiff, )
vs. )
)
)
CAVALRY INVESTMENTS, LLC )
and )
CAVALRY PORTFOLIO SVCS )
) CLASS ACTION
Defendants. )
) JURY TRIAL DEMANDED
PLAINTIFF LARKAY D. WESLEY’S MEMORANDUM OF LAW IN SUPPORT OF HER RESPONSE IN OPPOSITION TO DEFENDANTS CAVALRY INVESTMENTS, LLC AND CAVALRY PORTFOLIO SVCS’S
MOTION FOR JUDGMENT ON THE PLEADINGS
Plaintiff Larkay D. Wesley, through counsel, hereby respectfully submits this Memorandum of Law in opposition to Defendants Cavalry Investments, LLC and Cavalry Portfolio Svcs’s (“Cavalry”) Motion for Judgment on the Pleadings (“Motion”). For the reasons set forth below, the first part of Defendants’ Motion should be denied.
I. INTRODUCTION
This is a consumer class action brought under the Fair Debt Collection Practices Act, 15 U.S.C. §§ 1692, et seq. (“FDCPA”), a federal statute that prohibits debt collectors from engaging in abusive, deceptive and unfair collection practices. Plaintiff claims that Defendants systematically violate the ...
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August 11, 2009 – 6:18 pm
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July 9, 2009 – 7:50 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ANNA ELIZABETH PIRES )
)
Plaintiff, Hobgoblins 2 film ) Civil Action No.
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CHOICEPOINT SERVICES INC. )
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CHOICEPOINT INC. )
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Defendants. )
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COMPLAINT
I. Preliminary Statement
1. This is an action for damages brought by an individual consumer against the Defendants for violations of the Fair Credit Reporting Act (hereafter the “FCRA”), 15 U.S.C. §§ 1681 et seq., as amended, and various other state laws.
II. Jurisdiction and Venue
2. Jurisdiction of this Court arises under 15 U.S.C. § 1681p, 28 U.S.C. §§ 1331, 1337, and supplemental jurisdiction exists for the state law claims pursuant to 28 U.S.C. § 1367.
3. Venue ...
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July 9, 2009 – 7:47 pm
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
SANDRA CORTEZ )
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Appellant/ )
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TRANS UNION, LLC )
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Cross-Appellant )
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APPELLANT/CROSS-APPELLEE SANDRA CORTEZ’S
RESPONSE AND REPLY BRIEF
In this third step brief, Appellant/Cross-Appellee Sandra Cortez (“Cortez”) hereby responds to Appellee/Cross-Appellant’s Trans Union, LLC’s (“TU”) opening brief and also replies to TU’s response to her opening brief.
As more fully set forth below, with respect to Ms. Cortez’s appeal, this Court should vacate the District Court’s order of September 13, 2007, which conditionally granted a new trial and should further reinstate the jury’s verdict.
With respect to TU’s appeal, this ...
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July 9, 2009 – 7:44 pm
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA
____________________________________
Karen A. Barel, on behalf of herself )
and all others similarly situated, )
)
Plaintiff, ) C. A. No. 06-2372
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Bank of America, )
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____________________________________)
ORDER
AND NOW, this _____ day of _____________, 2007, upon consideration of Defendant Bank of America’s Motion for Summary Judgment, and Plaintiff’s Response thereto, it is hereby ORDERED that said Motion is DENIED.
_____________________________
Surrick, J.
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA
____________________________________
Karen A. Barel, on behalf of herself )
and all others similarly situated, )
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Plaintiff, ) Midnight ...
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July 9, 2009 – 7:43 pm
FRANCIS & MAILMAN, P.C.
Land Title Building, 19th Floor
100 South Broad Street
Philadelphia, PA 19110
(215) 735-8600
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
FREDERIC , on behalf of himself )
and all others similarly situated, )
)
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VISA U.S.A., INC., )
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Defendants. )
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CLASS ACTION COMPLAINT
I. NATURE OF THE ACTION
1. This is a consumer class action arising out of Defendants’ deceptive and misleading practices in making available for purchase and use the All-Access Visa Gift Card in the State of New Jersey. Defendants’ practices violate the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et seq. (“CFA”), the New Jersey Gift Card Act, N.J.S.A. 56:8-110 ...
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July 9, 2009 – 7:41 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
GRACE LAWRENCE, A Knights Tale buy )
on behalf of herself and all )
others similarly situated, Shattered movie download )
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PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF HER RESPONSE
IN OPPOSITION TO DEFENDANT’S MOTION ...
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July 8, 2009 – 6:24 pm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
GARY SERRANO, )
on behalf of himself and all others )
similarly situated, )
)
Plaintiff, ) Civil Action No. 07-4563
vs. )
)
STERLING TESTING SYSTEMS, INC., )
)
Defendant. ) CLASS ACTION
)
PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF HIS RESPONSE
IN OPPOSITION TO DEFENDANT’S MOTION TO DISMISS
Plaintiff Gary Serrano, through counsel, respectfully submits this memorandum of law in support of his response in opposition to Defendant Sterling Testing Systems, Inc.’s Motion to Dismiss Plaintiff’s Complaint pursuant to Fed. R. Civ. P. 12(b)(6) (“Motion”) (Docket No. 8). Defendant’s Motion should be denied because Plaintiff has properly pled a cognizable cause of action under the Fair Credit Reporting Act 15 U.S.C. §§ 1681, et seq. (“FCRA”).
Specifically, Plaintiff brings this class action claiming that Defendant violates the FCRA ...
Posted in Sample Legal Briefs & Pleadings | 1 Comment »
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