As you may recall, in our July 2014 article “More Traps for Debt Collectors Attempting to Collect Time-Barred Debts,” the Eleventh Circuit surprised the collection industry in Crawford v. LVNV Funding, LLC by ruling that the filing of a proof of claim to collect a time-barred debt in a Chapter 13 bankruptcy violated the Fair Debt Collection Practices Act (FDCPA).
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