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In Swelnis v. Universal Fidelity L.P., 2014 WL 1571323 (N.D.Ind. 2014), Judge Cherry addressed discovery in an FDCPA class action.  First, Judge Cherry required disclosure of “Training Materials”: Plaintiff's Interrogatory No. 9 and Document Request Nos. 4–6, 8, and 11 each seek infor-mation—specifically: training manuals and other relevant documents—that relate to Defendants' Af-firmative Defense of bona fide error. Defendants objected… Read More

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”)… Read More