Nagle & Zaller, P.C. v. Delegall
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The Court of Appeals held that a law firm that engages in debt collection activities on behalf of a client, including the preparation of a promissory note containing a confessed judgment clause and filing of a confessed judgment complaint to collect a consumer debt, is not subject to the provisions of the Maryland Consumer Loan Law, Md. Code Comm. Law 12-301, et seq.
This case arose from debt collection activity by Nagle & Zaller, P.C., a law firm, on behalf of its clients. Plaintiffs filed a complaint alleging that Nagle & Zaller violated the Maryland Consumer Loan Law (MCLL), Md. Code Comm. Law (CL) 12-301, et seq. Nagle & Zaller filed a motion to dismiss, alleging that the MCLL did not apply to the debt collection activities alleged in the complaint. The federal court entered a certification order requesting that the Supreme Court answer whether a law firm that undertakes debt collection activity is required to be licensed under the MCLL. The Supreme Court answered the question in the negative, holding that the MCLL did not apply to the transactions at issue.
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