PATTERSON v. HOWE

No. 22-2602, No. 22-3083.

96 F.4th 992 (2024)

Mark A. PATTERSON, Plaintiff-Appellee, v. Howard HOWE, Defendant-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided March 21, 2024.


Attorney(s) appearing for the Case

Robert E. Duff , Attorney, Indiana Consumer Law Group/law Office of Robert, Fishers, IN, for Plaintiff-Appellee.

Christopher C. Murray , Attorney, Ogletree, Deakins, Nash, Smoak & Stewart, P.C., Indianapolis, IN, for Defendant-Appellant.

Before Easterbrook, Hamilton, and Pryor, Circuit Judges.


Attorney Howard Howe filed suit for a client in an Indiana state court against Mark Patterson to collect an unpaid educational debt. Along with the complaint and summons, Howe served Patterson with four requests for admission, as allowed by Indiana law. Howe did not warn Patterson that the requests would be deemed admitted...

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