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Do not have a legal assistant cobble together something from a legal form book, file it, and expect a settlement.  Prepare the case thoroughly before filing.

Is the claim based upon a “consumer debt?”

Who are the defendants?  Most credit card companies operate through subsidiaries.  Bank of America has a subsidiary called FIA Card Services.  Capital One Bank, N.A., uses “Capital One Services, LLC” to collect from consumers in California.

Are there just FDCPA violations?  Are there violations of other statutues?  When did the violation(s) occur?  What is the Statute of Limitations?  Is it one continuing course of conduct or a series of separate violations?  Were there violations of the federal Fair Credit Reporting Act?  TILA?  B&P 17200?  Consumer Legal Remedies Act?  Common law violations?

Have similar cases been filed against this / these defendants in other states or other jurisdictions?

Federal Preemption?

Hint: Prepare an appendix of out-of-state authorities that pertain to legal issues in your case.

What discovery will you need to conduct.  Will you need to file a motion for discovery of key documents which are in the possession of the other side?

What, specifically, are your damages?  How will you prove damages?

Do you have a “killer” piece of evidence?  Smoking gun?

Hint.  Draft Jury Instructions when you draft the complaint. 

Hint.  Use the exact language of your proposed Jury instructions when you propound discovery, such as Interrogatories and Deposition Questions.