Violation Of Fair Debt by tessafree



I. What is the Fair Debt Collection Practices Act? To whom does
it apply?

    The Federal Fair Debt Collections Practices Act is a law

passed by the United States Congress to eliminate abusive,

harassing, and unfair practices in the collection of debts. This

law applies only to credit collection agencies and lawyers

attempting to collect debts for another person or company. It is

important to note that this law does not apply to creditors

attempting to collect debts owed to themselves.

    In an effort to collect debts, credit collection agencies

and the attorneys who represent creditors and collections

agencies, may make demands on debtors (people who owe money) in

order to collect delinquent debts. Some demands are legal and

others are not. Some agencies and their counsel may play on

peoples guilt feelings and may attempt to persuade people who are

struggling to pay their bills, to pay bills that creditors have

little or no chance to collect in any other way. They may attempt

to get debtors to forget their good judgment and to pay bills out

of the order of their importance or in a manner not in the

debtor's best interest. (For example creditors may try talking a

debtor into making credit card payments when the debtor is more

importantly attempting to avoid a possible utility shut off,
eviction from their residence, or land contract or mortgage


II.   What is an Unsecured Debt?

      An unsecured debt is a debt that is not supported by an

express agreement that the creditor can ask for the return of the

goods purchased if a debtor does not pay. Examples of unsecured

debts are medical bills, small consumer loans and virtually all

credit card debt. Secured debt involves an agreement regarding

the return or "attachment" of a "secured" item, such as the

repossession of a car because of money owed on the car or

foreclosure on a home.

III. What Can Unsecured Creditors Legally Do In Attempting to
Collect A Debt?

      Credit collection agencies and their attorneys are legally

allowed to do only the following three things in an effort to

collect an unsecured debt:

      1.   Tell the debtor that the creditor will stop doing
           business with the debtor if the bill is not paid.

For example, if you don’t make regular payments on your credit

card, the credit card company can cancel the credit card.

Someone who provides personal services to you (like a

doctor/dentist/lawyer) may refuse to provide future service if
you currently owe money to them and if they appropriately follow

the ethical rules guiding their profession in withdrawing from

current service (if the debt is part of an ongoing service).1

     2.   If the debtor disagrees with the debt, the
          attorney/collection agency may still report the default
          on the debt to a credit reporting agency.

      The attorney/collection agency must tell you that if you do

not pay the bill, they will report your debt to a credit

reporting agency, and that the debt may affect whether you

receive credit in the future. In many ways, however, this threat

is a hollow threat because most credit reporting agencies already

know whether you have paid your bills on time.

     Most credit card companies and businesses automatically and

regularly report whether you pay your bills on time to credit

reporting agencies. The primary creditors (those who are owed the

money) do not have to contact you before they report your payment

history but are legally obligated to report correct information.

 The credit reporting information threatened by the attorney or

collection agency is therefore often already on your credit

report before you are threatened with reporting. The only way to

stop the reporting of any delinquencies is to become current on

your bills.

     Therefore, if you have too many bills to pay, you should not

1 There may be exceptions to this rule -such as a utility company who is
the only service provider in town. See the Utility Rights Section of
this manual and/or legal counsel if faced with this dilemma.
bow to threats and pay a particular bill solely   because someone

says it will "save your credit."   You should consider your most

basic bills first – for example your rent or house payment, heat

and   utilities.   You may then want look at any “secured debts”,

such as your car. If you are not sure what bills to pay, talk to

a credit counseling agency or other organization that can help

you figure out the best way to work your way out of debt.

      3.   Collection agencies and attorneys can file a lawsuit to
           collect the debt.

      It is difficult to predict when someone will actually file

a lawsuit on any unsecured debt. Lawsuits are expensive and many

creditors will not sue on a small debt.

      If a lawsuit is filed, however, you do have the right to

respond - to explain why the debt has not been paid, to raise

defenses, if you have any defenses, and to negotiate a


      If a lawsuit is filed, it is important to respond. Your

choice to do nothing cannot and will not stop a creditor or their

agents from taking a judgment against you. You do not have to

have an attorney to respond. You may wish to hire an attorney but

you are also allowed to represent yourself.

      Worst case scenario - even if a judgment is taken against

you, you still have rights. You may appeal the judgment if you

think it was wrongfully entered. Alternatively, you may, in a

writing called a motion, ask a Court to   enter an installment

payment order. You may still work out a payment plan with the
person to whom you owe money. If you work out a payment plan that

differs from a Court Order, it is important to get the same in

writing and to let the Court know of the alternate agreement.

Once a judgment is paid it is important to have the creditor file

a "satisfaction" of judgment with the Court and to report that

paid status to credit reporting agencies.

      Under Michigan law, a judgment is "good" - can be collected

upon- for ten years. This is true if the judgment is granted by a

Court " of record." In Michigan, for purposes of judgments,

Courts "of Record," are the State of Michigan District and

Circuit Courts, the Probate Courts (although they rarely issue

monetary judgments) and the U.S. District Court. There are

certain ways in which a judgment can be "revived" - that is, the

ten year time period can be made longer. If a judgment taken

against you is over ten years old, and there is an attempt to

collect that debt, it is important to see an attorney to make

sure the debt has not been "revived." If you are dealing with a

"foreign" judgment - a judgment taken out of the State of

Michigan, you should contact an attorney to see if any other debt

collection law applies.

IV.   Your Right To Dispute Your Debt

      A   collection agency or collection attorney, must notify you

that you can dispute your debt and that you have a certain time

period (30 days by law) to do so before the agency/attorney can

report the past due debt to any collection agency.
     Collection agencies and collection attorneys are required

by law to investigate disputed debt and to report back to you

concerning the validity of any disputed debt.    If you do dispute

the debt,    for example,   you think you do not owe all or part of

the money demanded,   do not ignore the deadline for telling the

attorney/collection agency about your dispute.    The

agency/attorney cannot legally report the debt if the law is not


III. What Collection Practices are Illegal Under the Fair Debt
Collection Practices Act?

    A collection agency or a collection lawyer on behalf of a

collection agency or creditor is prohibited from doing certain

things under the Fair Debt Collection Practices Act. The

following is a list of some of the more common yet prohibited


    1. Talking to Other People about Your Debt     -- A credit

collection agency or collection attorney cannot talk or write to

your friends, your family, your employer, your neighbors, or

anyone else (for example, landlord, FIA case worker) about a debt

you owe, unless you or a Court have given them permission to do

so. There are a few exceptions to this rule. A collection agency

or attorney may legally contact a credit reporting agency, other

known creditors, your spouse or a co-signer on the debt, or your

parents, if you are a minor. Your friends, family, neighbors,
employer or others listed above may be contacted only if the

agency is attempting to find you. The agency or attorney cannot

identify themselves as a debt collector nor may they say you owe


    2. Contacting     You At Odd Hours -- A collection agency or

collection attorney or their staffs cannot contact you at odd or

inconvenient hours. The hours between eight a.m. and nine p.m.

are considered normal. However if you work a night shift, and

that is known by the creditor, even the hours between eight and

nine maybe considered inconvenient if they are meant to deprive

you of sleep.

    3. Contacting You at Inconvenient Places -- A collection

agency or collection attorney cannot contact you at inconvenient

places such as a friends' house or a hospital.

    4. Contacting You at Work Is Against Work Rules -- A

collection agency or collection attorney may not call you at work

if they know an employer prohibits personal calls.

    5. Contacting You Instead of Your Lawyer --    A collection

agency or collection attorney cannot contact you if you are

represented by an attorney with regard to the debt, unless you

and the attorney agree to that communication or if the attorney

fails to respond to the collection agency.

    6. Making Repeated Phone Calls -- A collection agent or

collection attorney   may not make repeated   telephone calls

within the same day or week as a way of harassment.
    7. Making False Threats -- A collection agency or collection

attorney may not make false threats such as criminal prosecution

(these are civil matters - there is no debtor's prison) or

threats to call the FIA with regards to your rights to your

children, reporting you can't provide for them because of your


    8. Using Foul Language -- A credit collection agency or

collection attorney cannot use foul, abusive or obscene language

in the collection of a debt.

    9. Hiding Their Identity -- A credit collection agent or

collection attorney must identify themselves to you, the debtor,

and the creditor they represent to you.

    10. Making their papers look like Court papers -- A credit

collection agency or collection attorney cannot simulate legal

process. This means they cannot make their letters and notices

look like Court papers if that is not the true status of the


    11. Using a Lawyer’s Letterhead -- A credit collection

agency cannot use a lawyers letter head if a lawyer is not

signing or reviewing the letters.

    12. Contacting You After You Send a “Cease Letter” -- A

credit collection agency or collection attorney cannot contact

you after you send them a “cease letter” which tells them not to

contact you any more unless a case is filed in Court.   (See

attachments and sample letters.)    While not required to do so,
creditors collecting their own debts will often stop contacting

you after such a letter.

    13. Misrepresenting Something About the Debt -- A credit

collection agency or collection attorney cannot misrepresent the

character, amount owed, services rendered, or status of a debt.

For example a collection agency cannot make reference to a

judgment that has never been taken.

    14. Publishing Debts -- A credit collection agency or

collection attorney cannot publish a list of debtors or debts

owed nor may they threaten to do so.

    15. Threatening That You Will Lose Your Children Or Welfare

Benefits -- A credit collection agency or collection attorney

cannot threaten loss of child custody or welfare benefits if a

debt is not repaid.

    16. Idle or Inaccurate Threats of Garnishment or Arrest -- A

credit collection agency or collection attorney cannot threaten

garnishment or arrest for consumer credit fraud if the collection

agency cannot lawfully do so, or if lawful, if they have no

intent to follow through on this action. For example, garnishment

is almost always prohibited as a pre-judgment remedy and is

allowed only after a judgment and then only when using procedures

prescribed by court rule and statute.

    17. Threats of repossession without the legal right   -- A

credit collection agency or collection attorney cannot threaten

self help repossession of goods if the right does not exist, by
virtue of a security agreement, and debtors cannot be threatened

with the same if there is no intent to follow through with this


    18. Depositing Post-dated Checks -- A credit collection

agency or collection attorney cannot deposit postdated checks

before the dates allowed on the face of the check.

    19. Not telling you that they are trying to collect a debt -

A credit collection agency or collection attorney cannot fail to

notify you that their call, visit or letter is an attempt to

collect a debt.

    20. Creating or Threatening additional expenses -- A credit

collection agency cannot create additional expenses (such as

collect calls) nor threaten additional expenses (attorneys fees)

as part of the collection process and unless they are legally

entitled to those fees and expenses. They must be authorized by

their client to collect them. For example, many collection

attorneys represent various creditors in exchange for a

percentage of the debt collected. They generally cannot charge an

hourly fee to you if they are not entitled to collect one or do

not intend to sue for the equivalent of hourly fees. A judge may

however award a statutory attorneys fee (a set amount allowed by

law) if that is appropriate to the judgment taken. (Actual costs

for collection may be allowed if the costs were necessary to the

collection of the debt.)
    21. Writing You in a Way That Tells Others You Owe a Debt –-

A credit collection agency or attorney cannot use symbols or

words on a post card or envelope in a way that the general public

would know that the correspondence is for the purpose of

collecting a debt owed.

IV. What Can You Do if an Attorney/Debt Collector Violates this

If a collection agency or collection attorney violates the Fair

Debt Collection Practices Act, you can bring a lawsuit in state

court or federal district court. Class action (groups of

similarly situated individuals) lawsuits are also available. If

you win, you can receive an award of $1,000.00 for each violation

of the act.   If you suffer a loss of money that is

greater than the $1,000 , you can ask for your actual loss,

along with reasonable attorney fees and the costs of suit.      Law

suits for violations of the act must be brought within one year

of the alleged violation of the act.   You can also add other

claims you may have such as consumer protection act claims.

     In addition, written complaints about a Credit Collection

Agency can be filed with the Federal Trade Commission and the

State Attorney Generals Office.   The State Bar Association may

also be able to discipline a collection attorney who has violated

the act.

    If you are being sued for a debt by the collection agency or

attorney, you may be able to raise violations of the Fair Debt
Collection Practices Act as a defense or offset against your


    Many legal services programs provide legal counsel for low

income individuals for either direct representation or referrals

to private pro-bono counsel with regard to debt collection

matters. Some pre-paid legal services programs made available to

employees or union members, like the UAW-GM Legal Services, have

developed an expertise in consumer law and also provide advice

and representation to qualified individuals.   Private attorneys

may take these types of cases based on the availability of legal


    Attorneys, in deciding whether to take these cases, look to

the merit of the case and the relative proof problems they must

overcome in order to prove violations of the law. In an FDCPA

violation case, an attorney must be able to demonstrate in open

Court that the violations did occur and any damages that were

suffered by the debtor as a direct result of a violation of the

act. It is important, therefore, that all documents, notices and

correspondence sent to the debtor from the collection agency

and/or attorney be kept.    Copies of any responses from the debtor

should also be available.   If the source of the problem is

telephone communications, phone logs should be maintained

detailing the time the calls were made (including time of day),

and what was said. Names of witnesses to violations should be

kept. Evidence of damages resulting from the violation should be
kept. For example, if a person loses a job or is disciplined as

the result of repeated dunning telephone calls, the damage should

be noted. If a person's reputation is harmed, how that occurred

and its possible economic effect should be noted. If a potential

client can bring concrete information concerning an FDCPA

violation to a lawyer, it may   greatly increase the chances of

acceptance of such a case by a lawyer.

V. Strategies for Dealing With Creditors Collecting Debts

     Over extended debtors often are honest everyday people who

find themselves dealing with financial or personal circumstances

they are unable to resolve or are uncertain about resolving.

Rarely are "debtors" the stereotypical intentional "deadbeats" or

criminals waiting to defraud their creditors. Many people have

accrued debts, having every good intention of paying back their

creditors - and then have found themselves faced with the loss of

a job, a divorce, the death/disability of a primary income

provider or a medical or other emergency that has wreaked

financial havoc in their lives. Some people have limited skills

in financial planning and handling money and do not use good

judgment in acquiring things and accruing debt. The ideal

solution or preventive advice for these problems is to tell the

debtor to budget his/her money and to never accrue debt that

cannot be paid off in case of an emergency.

    We, however, do not always live or act in an ideal world.

This article does not advocate not paying your bills nor is its
purpose to teach people how to avoid creditors and debt payment.

The following strategies are suggested to help the

client/consumer to deal with and to prioritize debt, as a

temporary measure, when someone finds themselves unable to pay

some or most of their bills.

    1. Prioritize bills/ debt. Stick to your priorities.

If you have too little money to pay your bills- determine which

bills you must pay - which bills are essential to your everyday

living - and pay them. Bills falling into this category are

allowances for food, utilities, shelter (including delinquent

property taxes and health care -especially medically required

prescriptions. Whenever possible, pay rent or mortgage payments,

buy groceries, decide if a car is a necessity if you own one, pay

all or enough of your utilities to avoid shut off, always pay for

necessary medical care and prescriptions. You should seek help if

you cannot stay current with necessities by contacting private

and public agencies designed to help with those problems. A rule

of thumb, with the exceptions already noted, is to pay secured

debt first.

    Next determine which other secured debt (car loans or

equipment loans) and special remedy debt (income taxes, student

loans which cannot be deferred, child support) is owed and to the

best of your ability pay them. Congress has given the IRS and

other Government insured lenders, like student lenders, some

extraordinary remedies in the form of liens and tax intercepts
which should cause you to view these debts as medium to high

priorities. Finally if there is money left over - pay the

unsecured debt.

    Use your head - do not pay the creditor or collection agency

screaming the loudest. For example, do not let a credit card

creditor or an agent talk you into paying off your credit card

debt if you are facing a utility shut off or if your mortgage is

about to be foreclosed or if you are diabetic and you are running

low on insulin. If you own a home, DO NOT use it as collateral to

pay off unsecured debt if there is even the slightest chance you

will be unable to keep up with the payments. An attempt at

maintaining your credit rating is insignificant if you risk

homelessness or yours' or your families' health.

    A classic nightmare case for a debtor and a debtor's

attorney is demonstrated by the following example of action on

skewed priorities. A disabled man comes into an attorney's

office. His only source of income is SSI. Before his disability,

he bought a home and had accrued approximately two thousand

dollars worth of consumer card debt. He felt very guilty about

the credit card debt and that guilt was fired by the regular

phone calls and dunning letters he received from collection

agencies. He is a very proud guy and the debts he couldn't pay

made him feel ashamed.

    He decides a home equity loan (which amounts to a new

mortgage with no home equity) is just the solution to his
problems. After all didn't that ad on TV suggest that your home

could be your best friend - the young guy in the ad looked pretty

sharp. He does not review the paperwork with anyone other than

the lender. He doesn't want anyone to know he can't pay his

bills. He borrows against equity in his home and pays off his

credit cards and his old mortgage. He is issued a brand new

mortgage - with larger monthly payments at a higher interest

rate. He is debt free except for the mortgage.

     A month later he is hospitalized as the result of the

disability. While hospitalized he does not make the monthly

mortgage payment on time. He immediately falls behind and after

two months of default he is notified the mortgage company has

shipped the matter to legal counsel for foreclosure by

advertisement. Now not only does he have to pay the arrearage but

the mortgage company is demanding an attorneys fee of almost a

thousand dollars. He thinks he can make up the arrearage    - but

he cannot pay the attorney’s fee. The Sheriff's sale is in a

month. He paid on the old mortgage for ten years.

    Is this legal? Yes. What can I do now to save my home? Not

much if the paperwork is in order and meets all technical

requirements of the law. The only hope here for the debtor is

that payments can be negotiated with the mortgage company or its

counsel -knowing all the while the mortgage company is not

legally required to allow for lower/lesser payments. In this case

bankruptcy is not an option to save the home because there was no
debt other than a mortgage - a mortgage with no equity. Because

of the sympathetic nature of some cases and to avoid the need to

resell the home, many lenders will renegotiate such a loan.    If

they don't - absent some type of hardship deferment- the client

will lose his home. The tragedy is the "home equity" loan was

unnecessary because the credit card debt was not collectible. His

income- SSI- would not have been attachable even if the credit

card company had sued him and gotten a judgment. He risked a

priority in order to pay a non-priority debt and is now at

substantial risk of becoming homeless. (Cross Reference to Manual

Section ____; Attachability of welfare benefits.)

     2. Call your creditors. Be Honest. Work out repayment plans
only if and when you can pay for necessary living expenses.

    Stopping calls -especially at inconvenient times -or

stopping dunning letters may be as easy as calling your unsecured

creditors as soon as it becomes evident you cannot pay bills. Be

honest in explaining the circumstance. If you are laid off or ill

and know when you will return to work-give the creditor basic

information concerning that. Explain that you will pay the debt

back when it is possible. Explain where the debt falls on your

list of priorities. Do not enter into a repayment plan, no matter

how tempting, unless you are certain to be able to follow through

with it. Never be talked out of your debt priorities. Collection

agents, no matter how sympathetic they are, do the work they do

as a way of making a living. Their priority is to get you to pay
that bill. This call will only buy time - it will not waive your

debts and it will not save secured items like cars from being


3. Find out what social service agencies, public and private, are
available to help you pay priority debts. Contact them.

    There are public and private social service agencies

available for emergency relief assistance and help with income

maintenance.   Through the State of Michigan, local county Family

Independence Agencies accept applications for State Emergency

Relief (SER) to help with emergency living expenses such as

housing. There are limitations on the availability and use of

State Emergency Relief Funds. Find out from your FIA case worker

or contact the FIA to arrange for a necessary case worker who can

help you with these funds. Funds are generally available for

example for emergency housing (mortgage, rent monies) and

household (utilities and food) needs. Your local FIA office

should also provide information to you with regard to your

eligibility for those public benefits programs available to you

such as food stamps, Medicaid, State Disability Assistance, child

care, etc. (If you feel you have been unfairly denied a form of

public assistance, contact your local services provider to review

that determination).

     The Social Security Administration should be contacted if

you are no longer working due to a disability to review your

eligibility for Social Security Disability and Supplemental

Security Income.
       If you are unemployed the Michigan Employment Security

Administration (MESA) should provide information on unemployment

eligibility and can explain their remaining job search aids to


       Private emergency providers should also be contacted. The

services they provide may extend from food vouchers to emergency

shelter to grants or vouchers for the payment of rent, utility

bills, prescription needs, meals, clothing and personal hygiene.

       Churches, food pantries, soup kitchens, homeless shelters,

domestic violence shelters, and the Salvation Army are the best

known providers of these services. It is important to know what

restrictions they place on their services. Often emergency

providers are networked so they are able to make referrals for

other needs. Community Mental Health providers are available for

counseling and can also help to make referrals to programs that

provider. If you are laid off and belonged to a union while

employed, you should contact your union representative also to

see if the union provides some year round and/or seasonal

assistance to its membership.

4.Be informed with regard to the nature of the debt owed and any
possible deferments or waivers for which you may be eligible.

       It is important to know whether the debt you owe is secured

or unsecured. Secured debt may provide for the placement of liens

or the attachment of certain property or goods or real property.

This may help you to determine debt priorities. Car loans and

mortgages are classic examples of secured debt. Mechanics liens
can be placed on vehicles and contracts liens can be place on

homes for   repair until those debts are paid. Unsecured debt

requires that the debt be reduced to judgment before many of

these remedies are available to creditors.

    Certain other debts such as student loans may provide for

hardship waivers or loan deferments. Because these debts often

require repayment before any further education maybe undertaken

and give the creditor certain extraordinary collection

possibilities, tax refund intercept among them, it is important

to know what rights you have available to receive temporary or

permanent relief with regard to these debts. Contacting your

lender and/or the legal services agency in your area will be to

your benefit.

5. Send a Cease Letter.

 In order to avoid harassing telephone calls and contacts you

may contact the collection agency or attorney and demand that

they cease contacting you. Federal law requires that creditior

collection agencies and collection attorneys cease contacting you

if you make a written request that they cease contacting you. You

need not state the reason for the request. Note this will not

prevent the collection agency/attorney/ or creditor from suing

you. It demands they either establish their case in court or stop

contacting you. Please see Exhibit ___ for an example of a cease

6. An Attorney Letter A letter to the credit collection agency or

the collection attorney from an attorney may have the effect of a

cease letter and sometimes add credibility to that effort. Note

that an attorney is not necessary to the sending of a cease

letter. If you wish to pursue an action against the credit

collection agency or collection attorney for violations of the

Federal Debt Collection Practices Act a demand letter of this

sort may be appropriate.

7. Work Out Agreement A debt collection agency or collection

attorney is likely to cease contacting you once a payment plan is

worked out with your creditors. As discussed previously, a work

out agreement should always take into consideration whether the

debt is a priority, and whether you are truly financially able to

abide by its terms. Never work out a payment plan with a creditor

while you are in bankruptcy or if you are contemplating

bankruptcy without the knowledge or advice of counsel. There are

specific rules regarding preferential treatment of creditors that

may be violated by working out such independent agreements

without specific advice from your counsel to do so.

8. Contact Government Agencies if the Collection Agency or
Collection Attorney Are using Abusive Practices.

Contact the Federal Trade Commission, Bureau of Consumer

Protection, Washington D.C. if you are being harassed in

violation of the Federal Collection Practices Act. Copies of the

letter noting the violations should also be sent to the Consumer

Protection and Charitable Trusts Division of the State Attorney
General's Office at P.O. Box 30213 Lansing, Michigan, 48909, and

to any local consumer protection division of the County

Prosecutor's Office and/or the County Chamber of Commerce and

Better Business Bureau.

9. Contact Legal Counsel and Discuss the Possibility and
Appropriateness of filing a Chapter 7 or Chapter 13 Bankruptcy.

As a last resort, a debt may wish to consider filing bankruptcy

to provide for the elimination or repayment of debt. There are

two types of personal bankruptcies - a Chapter 7 ( complete

discharge of debt) and Chapter 13 (repayment plan of debt ). Both

types of bankruptcies provide specific debtor relief and

benefits. Not all debt is dischargeable in bankruptcy and

bankruptcy is not a cure for all types of debt problems.    An

attorney should be able to discuss the effects of the

bankruptcies on your credit and to discuss which debts can be

eliminated through a bankruptcy filing and advise you

accordingly. Additional details regarding consumer rights and the

limitations of bankruptcy in eliminating debt are available in

this manual under the Bankruptcy heading.

Acknowledgements and Bibliography:

The drafter of this section gratefully acknowledges, in addition

to the statutory materials themselves, the use of the following

in the preparation of this section:
Surviving Debt: A Guide for Consumers Published and edited by

the National Consumer Law Center, Inc. New (2nd) Revised Edition,

Boston, Massachusetts (1996) Available through the National

Consumer Law Center, Publications, NCLC, 18 Tremont Street,

Boston MA 02108 (617) 523-8089


You and the Law: Your Legal Guide to Consumer Credit   Published

by the American Bar Association, Publication Division, 1988;

Available as part of the You and the Law series through the

Public Education Division, American Bar Association, Order

Fullfillment, 750 North Lake Shore Drive, Chicago, Illinois,

60611. Note product code number: 235-0010.

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