ROGERS, Circuit Judge. Defendant Harold Simpson appeals the sentence and order of restitution imposed for his crime of mail fraud. For several years, Simpson underreported payroll information for his businesses to his workers’ compensation insurance carriers. The district court concluded that the “loss” caused by this conduct was the amount of additional premiums that the insurance carriers would have charged had they been given accurate information. The court then used those figures to calculate Simpson’s Sentencing Guidelines range and the amount of restitution due to the carriers. On appeal, Simpson argues that the proper measure of loss was not the unpaid premiums, but the amount of money that the carriers actually paid on claims. This argument fails, however, because what Simpson took through his deceit was insurance coverage, and the fair market value of that coverage was the amount of the unpaid premiums. We therefore affirm the judgment of the district court.

BOGGS, Chief Judge. Defendant Damon Alexander, Jr. appeals from the district court’s decision not to suppress the key evidence underlying his plea of guilty to charges of conspiring to possess cocaine and possessing cocaine and cocaine base. Alexander also appeals the district court’s denial of his motion to compel discovery of materials produced during an investigation of his alleged beating by a police officer. For the reasons stated below, we affirm.

COLE, Circuit Judge. Plaintiff Karen L. Jerman filed an action challenging the debtcollection practices of the law firm Carlisle, McNellie, Rini, Kramer & Ulrich (“Carlisle”), and Adrienne S. Foster, an attorney employed by Carlisle, (collectively, “Defendants”). Jerman claims that Defendants violated the Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692-92p, when they used allegedly deceptive forms to notify her of a foreclosure on her home. More specifically, Jerman claims that Defendants violated the FDCPA by representing to Jerman that her debt would be assumed valid unless she disputed the debt “in writing” even though the FDCPA does not require a written dispute. The district court granted Defendants’ motion for summary judgment, concluding that, although Defendants violated the FDCPA by instructing Jerman that she must dispute the debt in writing, Defendants qualified for the FDCPA bona fide error defense, 15 U.S.C. § 1692k(c). On appeal, Jerman asserts that the defense is not available. For the following reasons, we affirm.

COLE, Circuit Judge. A Cuyahoga County, Ohio three-judge panel convicted Reginald Jells for the murder of Ruby Stapleton and sentenced him to death on October 6, 1987. After exhausting direct and post-conviction remedies in the State of Ohio, Jells timely filed a petition for a writ of habeas corpus in the United States District Court for the Northern District of Ohio on October 27, 1998. The district court denied his petition on March 18, 2002. For the reasons below, we REVERSE the judgment of the district court.

CLAY, Circuit Judge. Plaintiff, Info-Hold, Inc. (“Info-Hold”), appeals the district court’s denial of its Federal Rule of Civil Procedure 60(b) motion for relief from an order, entered pursuant to a Settlement, Release, and License Agreement (the “Settlement Agreement”), dismissing Info- Hold’s patent infringement action, brought under 28 U.S.C. § 1338 (2000), against Defendant, Sound Merchandising, Inc. (“SMI”), doing business as Intellitouch Communications. Info-Hold contends that relief is warranted because (1) SMI fraudulently induced Info-Hold to enter the Settlement Agreement, and (2) SMI committed a material breach of the Settlement Agreement. For the reasons that follow, we AFFIRM the district court’s denial of Info-Hold’s Rule 60(b) motion.

ALICE M. BATCHELDER, Circuit Judge. Plaintiff–Appellant Brian Petty appeals the district court’s summary judgment and judgment on partial findings in favor of Metropolitan Government of Nashville-Davidson County (“Metro”) on claims that Metro violated his rights under the Uniformed Services Employment and Reemployment Rights Act of 1994 (“USERRA”), 38 U.S.C. §§ 4301 - 4334. Because the district court erred in its application of §§ 4312 and 4313, we reverse the district court’s grant of summary judgment for Metro on two claims asserted under these provisions, and order that summary judgment be entered in favor of Petty on those claims. Further, because the district court made errors of both fact and law in its judgment on partial findings under § 4311, we vacate that judgment.