In Devlin v. Law Offices of Howard Lee Schiff, P.C., 2013 WL 1459195 (D.Mass. 2013), Judge Dein ordered production of FDCPA manuals.

The defendant shall produce any manuals concerning debt collection that it uses for general training purposes, as well any specific handouts or materials that it uses for purposes of compliance with the Fair Debt Collection Practices Act (“FDCPA”) and which concern the provisions of the FDCPA that are at issue in this case.