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In Doyle v. Midland Credit Management, Inc., --- F.3d ----, 2013 WL 3242148 (2d Cir. 2013), the Second Circuit Court of Appeals found that no formal Rule 68 offer was required to moot a Plaintiff’s FDCPA case when the Defendant made an offer that would have fully satisfied the Plaintiff’s damages. Doyle contends that the district court erred in dismissing… Read More