Commercial Banking, Collections, and Bankruptcy

Wood v. Security Credit Services, LLC

Federal 7th Circuit Court
Wood v. Security Credit Services, LLC
Civil Court
Fair Debt Collection Practices Act
Citation
Case Number: 
No. 23-2071
Decision Date: 
January 28, 2025
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Reversed and remanded.
Judge: 
KOLAR

Plaintiff filed a lawsuit alleging that defendant violated the Fair Debt Collection Practices Act by communicating information about his debt to a third-party without noting that he disputed the debt. The district court granted summary judgment for the defendant. The Seventh Circuit reversed and remanded, explaining that a summary judgment was not proper where the record supported two interpretations of the defendant’s actions and understandings of its obligations under the law. (EASTERBROOK and HAMILTON, concurring)

Seeing Red: Transforming Anger into Healthy Skills for Healthy Living

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Trusts & Estates Section


1.0 hour MCLE credit, including 1.0 hour Professional Responsibility MCLE credit in the following category: Mental Health and Substance Abuse credit


Original Program Date: Tuesday, January 21, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 27, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Anger comes in many forms – from quiet disappointment to all-consuming rage – and springs from many sources, including perceived provocations, differences of opinion, fragile egos, and more. Don’t miss this opportunity to hear from our speaker, Lynette Hoy, as she explores the best methods for managing anger and coping with angry clients. Attorneys with basic practice experience who attend this online seminar will better understand:
  • The nature and physiology of anger;
  • How to express anger with respect, empathy, and assertiveness using research-based skills;
  • The strategies for coping with anger in personal and professional situations; and
  • Much more.

Program Coordinators:
Kerry R. Peck, Peck Ritchey LLC, Chicago
Colleen L. Sahlas, Law Offices of Hoy & Sahlas, LLC, Oak Brook

Program Chat Moderator:
Colleen L. Sahlas, Law Offices of Hoy & Sahlas, LLC, Oak Brook

Program Speaker:
Lynette J. Hoy, President, Anger Management Institute, Oak Brook
About the Speaker: Lynette Hoy is a Licensed Clinical Professional Counselor in Illinois and a National Certified Counselor. She is a Diplomate, Supervisor, Consultant, and Anger Management Specialist-V with the National Anger Management Association, as well as a Certified Clinical Trauma Professional by Evergreen Certifications. Mrs. Hoy has authored all the What’s Good About Anger? books and expanded workbooks and is a regular pre-conference workshop presenter and track leader for the AACC international conferences. Lynette oversees, authors, and publishes all courses and training curriculum for both the Anger Management Institute and CounselCare Connection, P.C. She is a crisis counselor with the R-3 Continuum, a crisis care network providing counseling and debriefing to various individuals and companies.


Program Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

2025: New Year, New Laws

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Bench & Bar Section


1.0 hour MCLE credit


Original Program Date: Thursday, January 16, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 28, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Don’t miss this annual hot topic program! Join us for this engaging seminar as Judge Jennifer Johnson presents a review of the new laws that will take effect throughout the new year. Topics include: an examination of the new statutory laws for 2025, a review of how the law has changed, and a look at which laws may be impacted in the future.

Program Coordinators:
Hon. Michael J. Chmiel , Twenty-Second Judicial Circuit, Woodstock
Edward Casmere, Norton Rose Fulbright US LLP, Chicago
Program Moderator:
Hon. Michael J. Chmiel, Twenty-Second Judicial Circuit, Woodstock

Program Speaker:
Hon. Jennifer L. Johnson , Twenty-Second Judicial Circuit, Woodstock


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Collecting Judgments & Bankruptcy Issues Series: What You Need to Know about Cryptocurrency

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Commercial Banking, Collections, and Bankruptcy Section


1.0 hour MCLE credit, including 1.0 hour Professional Responsibility in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit


Original Program Date: Wednesday, January 8, 2025
Accreditation Expiration Date: January 27, 2027(You must certify completion and save your certificate before this date to get MCLE credit)


Join us for Part 2 of this three-part series as we discuss collections in bankruptcy and the issues that can arise with cryptocurrency. Listen as our cybercurrency and forensic accounting expert offers information and strategies for collecting judgments and handling bankruptcy claims against cybercurrency assets.

Program Coordinators:
Samuel H. Levine, Downey & Lenkov LLC, Chicago
Nathan Lollis, Law Offices of Nathan Lollis, LLC, Chicago

Program Moderator:
Julia Jensen Smolka, Robbins DiMonte, Park Ridge

Program Speaker:
Stuart G. Berman, CFE, CAMS, PSP, RSA Risk Management & Investigations, Naperville


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Property Taxes in Chapter 13 Bankruptcies

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Commercial Banking, Collections, and Bankruptcy Section


1.5 hours MCLE credit


Original Program Date: Wednesday, December 18, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 28, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Get the best practice tips you need to help your Chapter 13 debtor/creditor clients as they deal with delinquent property taxes with this informative online seminar. Commercial banking lawyers, real estate practitioners, bankruptcy attorneys, and construction law counsel with basic to intermediate practice experience who attend this program will better understand:
  • How to pay off property taxes in Chapter 13;
  • How to confirm if there is a tax sale;
  • How to identify the tax buyer;
  • Receiving notice of a sale in error;
  • Who gets paid in Chapter 13;
  • How to ensure release of rights upon discharge;
  • How to get all interested parties to participate;
  • What happens upon dismissal or conversion;
  • What happens when checks are rejected;
  • Who files the proof of claim (and for what entity); and
  • Much more.

Program Coordinator:
Samuel H. Levine, Downey & Lenkov LLC, Chicago

Program Moderator:
Julia Jensen Smolka, Robbins DiMonte, Park Ridge

Program Speakers:
Paul M. Bach, Bach Law Offices, Inc., Northbrook
Claudia Badillo, Badillo Law Group, Chicago
Thomas H. Hooper, Chapter 13 Trustee, Chicago


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $52.50 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $105
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Collecting Judgments & Bankruptcy Issues Series: Understanding the Issues That Can Arise During Judgment Enforcements

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Commercial Banking, Collections, and Bankruptcy Section


1.50 hour MCLE credit


Original Program Date: Tuesday, December 17, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 28, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Join us for Part 1 of this three-part series as we discuss collections in bankruptcy, the issues that can arise in post-judgment collections, and potential resolutions to the conflicts your clients may face. Attorneys with intermediate practice experience who attend this online program will better understand the bankruptcy and collection process, as well as the options that are available to creditors when a debtor files bankruptcy, including actions seeking to dismiss the bankruptcy, deny discharge to the debtor, or file an adversary complaint against the debtor.


Program Coordinator:
Samuel H. Levine, Downey & Lenkov LLC, Chicago

Program Moderator:
Julia Jensen Smolka, Robbins DiMonte, Park Ridge

Program Speakers:
Nathan Lollis, Law Offices of Nathan Lollis, LLC, Chicago
Laxmi P. Sarathy, Klein, Daday, Aretos & O’Donoghue, Schaumburg


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $52.50 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $105
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

60 Artificial Intelligence Tips in 60 Minutes

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Standing Committee on Artificial Intelligence & the Practice of Law
Co-sponsored by ISBA Standing Committee on Legal Technology and ISBA Privacy and Information Security Section


1.0 hour MCLE credit, including 1.0 hour Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, and Sexual Harassment Prevention credit


Original Program Date: Friday, December 13, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 15, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Join us for this entertaining and educational session focused on the safe and efficient use of artificial intelligence in your practice. Our presenters will give you 60 rapid-fire practical tips and tricks for using several popular artificial intelligence tools and techniques in your daily workflow. Topics include: ChatGPT, privacy and security issues to be aware of, tech support, and more.

Program Speakers:
Aaron W. Brooks, Brooks Law and Consulting, LLC, Naperville
Bryan M. Sims, Sims Law Firm, Ltd., Naperville


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

6th Annual Abraham Lincoln's Legal Legacy: Lessons for Today's Lawyers - Democracy, The Constitution, and Lincoln the Lawyer/President - Part 2

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the Illinois State Bar Association
Co-sponsored by the Abraham Lincoln Association


2.75 hours MCLE credit, including 2.75 hours Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit


Original Program Date: Friday, September 6, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 6, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Don’t miss ISBA’s 6th Annual Abraham Lincoln’s Legal Legacy seminar as we study Lincoln’s actions as a lawyer and President in facing threats to democracy in America and the United States Constitution. The program takes place in Springfield, which was the center of Lincoln’s law practice and three partnerships, and where Lincoln developed his understanding of the democratic process and his interpretation of the Constitution. It was the venue for many of Lincoln’s significant trials, including the “Peachy” Quinn Harrison murder trial. Join us for this in-depth look at how Lincoln’s view of the Constitution changed over time and evolved into the use of his Presidential War Powers to advance the case of Union and emancipation. Additional topics include:
  • How the 1909 Centennial Celebration of Lincoln’s birth resulted in no minorities attending the festivities and how, at the same time in New York City, concerned citizens formed the NAACP to discuss and address racism and white supremacy in the U.S.;
  • The current ethical issues facing attorneys, including lawyer-client privilege, confidentiality concerns, and limits on lawyers and litigants’ speech during trials;
  • How future lawyers can research Lincoln’s legal career and cases;
  • What current and future lawyers can learn from Lincoln’s legal legacy; and
  • Much more.

Program Coordinators:
J. Steven Beckett, Steve Beckett Law Office LLC, Urbana
Hon. Ronald D. Spears (ret.), Spears Dispute Resolution LLC, Taylorville

Contemporary Ethical Issues*
Join us for a discussion on the ethical issues facing lawyers today, including lawyer-client confidences, confidentiality requirements, restrictions on speech by lawyers and clients during trial, and more.
Melissa A. Smart, Director of Education, Attorney Registration & Disciplinary Commission, Chicago

Looking for Lawyer Lincoln? How Future Lawyers Can Access Lincoln’s Legal Cases, Papers, and Career*
John Lupton, Illinois Supreme Court Historic Preservation Commission, Springfield

Lincoln’s Legacy as Lawyer/President*
This panel presentation discusses what current and future generations of lawyers can learn from Abraham Lincoln as a lawyer and a President.
Moderator: Hon. Ronald D. Spears(ret.), Spears Dispute Resolution LLC, Taylorville
J. Steven Beckett, Steve Beckett Law Office LLC, Urbana
Prof. Brian Dirck, Anderson University, Indiana
Guy C. Fraker, Attorney and Author, Bloomington
John Lupton, Illinois Supreme Court Historic Preservation Commission, Springfield


Program Information:
  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $96.25 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $192.50
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

6th Annual Abraham Lincoln's Legal Legacy: Lessons for Today's Lawyers - Democracy, The Constitution, and Lincoln the Lawyer/President - Part 1

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the Illinois State Bar Association
Co-sponsored by the Abraham Lincoln Association


3.0 hours MCLE credit, including 2.0 hours Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit


Original Program Date: Friday, September 6, 2024
Accreditation Expiration Date: January 6, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


 Don’t miss ISBA’s 6th Annual Abraham Lincoln’s Legal Legacy seminar as we study Lincoln’s actions as a lawyer and President in facing threats to democracy in America and the United States Constitution. The program takes place in Springfield, which was the center of Lincoln’s law practice and three partnerships, and where Lincoln developed his understanding of the democratic process and his interpretation of the Constitution. It was the venue for many of Lincoln’s significant trials, including the “Peachy” Quinn Harrison murder trial. Join us for this in-depth look at how Lincoln’s view of the Constitution changed over time and evolved into the use of his Presidential War Powers to advance the case of Union and emancipation. Additional topics include:
  • Lincoln’s representation in the high-profile “Peachy” Quinn Harrison murder trial. (Robert Hitt, a court stenographer at the time, recorded the trial and produced a trial transcript, which is now preserved at the Abraham Lincoln Library and Museum);
  • The 1908 Springfield Race Riot and how its violence and aftermath showed the nation that Lincoln’s struggle for freedom and equality for all citizens was far from a reality;
  • Much more.

Program Coordinators:
J. Steven Beckett, Steve Beckett Law Office LLC, Urbana
Hon. Ronald D. Spears (ret.), Spears Dispute Resolution LLC, Taylorville

Lincoln’s Evolving Views on the Constitution as Lawyer and President*
The program’s opening segment examines Lincoln’s loyalty to the rule of law and commitment to democracy and the rights enshrined in the Declaration of Independence, while at the same tine operating under a Constitution that protected slavery.
Prof. Brian Dirck, Anderson University, Indiana

Lincoln and the “Peachy” Quinn Harrison Murder Trial*
In 1859, a former law clerk of Lincoln’s was murdered, but Lincoln defended the accused, who happened to be the grandson of Reverend Peter Cartwright (who had run against Lincoln for office twice) and the son of a prominent political supporter. Don’t miss this in-depth look at one of Lincoln’s most high profile trials.
Guy C. Fraker, Attorney and Author, Bloomington

1908 Springfield Race Riot
This segment examines the events leading up to racial violence in Lincoln’s Hometown in August 1908, as well as its aftermath.
Kathryn Harris Former Division Manager of Library Services of Abraham Lincoln Presidential Library and Museum and Past-President of Abraham Lincoln Association


Program Information:
  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $105 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $210
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Mental Health 101: Strategies for Thriving, Not Just Surviving

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Young Lawyers Division


1.0 hour MCLE credit, including 1.0 hour  Professional Responsibility MCLE credit in the following category: Mental Health and Substance Abuse


Original Program Date: November 5, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­December 2, 2026 (You must certify completion and save your certificate before this date to get MCLE credit)


As attorneys, we work long hours, juggle multiple cases simultaneously, spend a large amount of time researching case law and preparing legal documents, and have strict deadlines that must be remembered (and met!) – all while staying up to date on the ever-changing laws and regulations that will impact our clients and practice. These mental demands can take its toll and leave us feeling deflated, burnt out, and running on fumes. Join us for this online seminar that teaches you how to create a better work-life balance, while still meeting your professional and personal goals. Topics include:
  • Positive strategies to enhance your self-care;
  • How to practice mindful stress management;
  • Tactics for building your resilience and mental fitness; and
  • How to find your perfect mental health space.

Program Coordinator:
Jason R. Blumenthal, Donahue & Rose P.C., Rosemont

Program Chat Moderator:
Courtney A. Berlin, Clifford Law Offices, Chicago

Program Speaker:
Erin Clifford, Clifford Law Offices, Chicago


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free