Law Firm's Garnishment Activities Do Not Violate FDCPA
Consumer Financial Services Law
DECEMBER 21, 2016
Courts have long debated the extent to which a debt collection attorney’s representations to opposing counsel or the court during the course of litigation may violate the FDCPA and the results from different circuits have varied greatly. See, e.g., Hemmingsen v. Messerli & Kramer, 674 F.3d 814 (8 th Cir. 2012); O’Rourke v. Palisades Acquisition XVI, LLC, 635 F. 3d 938 (7 th Cir. 2011); Miller v.
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