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10/17/13 DRAFT proposed amended complaint | Baker v Midland Funding, MCM and Bursey & Associates | Litigation Forum

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10/17/13 DRAFT proposed amended complaint
Filed on 10/20/13 and now waiting for Midland / Bursey responses opposing my motion for leave to amend.
October 17, 2013
9:21 pm
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christine
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May 5, 2013
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I know it would be helpful to be able to read the justice court filings, but I just haven't gotten to uploading them yet, hopefully soon.

Have to file by Saturday, would like to file tomorrow eve and appreciate any suggestions.

UPDATE: I just attached a new draft NOT redlined for easier reading.

 

10/26/13 UPDATE:

 

Attached are my motion, redlined proposed amended complaint, order and exhibits, filed electronically on 10/20/13.  I expect Midland and Bursey to oppose my motion for leave to amend the complaint and will update here.

 

 

July 17, 2014
9:19 pm
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christine
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The FINAL first amended complaint, substantially different than my proposed amended complaint as the court dismissed all FDCPA claims and the Bursey attorneys are no longer named as defendants and I also removed all FDCPA claims against Midland and MCM.   However, I will appeal the dismissal of the FDCPA claims as it is beyond absurd to grant collectors and debt buyers immunity for all violations one year after a lawsuit against a consumer was filed.  I'll get into more details when I have more time.

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