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DEBTOR-CREDITOR: The trial court did not err in permitting garnishment of a judgment-debtors funds held in a law firms IOLTA account, even though the judgment-debtor claimed that the funds represented a retainer for legal services, where the judgment-debtor presented no evidence of a retainer agreement or that any portion of the funds had been earned by the law firm, and where the judgment debtor failed to show that any of the statutory exemptions from garnishment applied.
A credit reporting agency can be liable where it overlooks or misinterprets documents in a court file, the 9th Circuit has ruled in reversing dismissal of the plaintiff's Fair Credit Reporting Act claim. A tenant reached a settlement of his landlord's claim for unlawful detainer. The original docket entry reflecting the resolution of the action included a court clerk's erroneous description of the settlement as a judgment after trial.
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