Jackson v. Red Rock Credit Solutions, LLC, 3:22-cv-04471

Plaintiff Kelly T. Jackson moved for default judgment against defendant Red Rock Credit Solutions, LLC.
Complaint alleges violations of the Credit Repair Organizations Act (CROA) and related California statute; Jackson seeks actual damages, attorney’s fees, and costs.
Red Rock is a Nevada LLC with its principal place of business in Tulalip, Washington; it defaulted (no substantive opposition).
The court denied the default-judgment motion without prejudice because Jackson failed to establish personal jurisdiction, failed to prove the amount of damages, and failed to adequately support her attorney-fees/costs request.
Jackson had asserted jurisdiction based on her residence and venue statute (28 U.S.C. § 1391); the court found that insufficient.
The court required a renewed motion addressing jurisdiction, damages proof, and fee documentation by October 2, 2023.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction	Court has jurisdiction because Jackson resides in N.D. Cal. and substantial events occurred there (citing venue statute)	No response on merits; Red Rock located in Nevada with principal place in Washington and no forum contacts alleged	Denied: plaintiff failed to show Red Rock’s minimum contacts or purposeful direction at California; plaintiff’s residence is insufficient
Damages proof	Seeks $997 in actual damages under CROA and Cal. Civ. Code	No opposition; no documentation submitted	Denied: amount of damages not proved with affidavit/declaration or other admissible evidence
Attorney’s fees & costs	Seeks $5,415 (but billing chart totals $3,886.50); includes time for arbitration demand	No opposition; submitted billing chart lacks declarations and rate justification	Denied: must provide supporting evidence for rates, itemized billing with attorney declaration, and explain recoverability of arbitration-related time

In re Tuli, 172 F.3d 707 (9th Cir. 1999) (judgment entered without personal jurisdiction is void and plaintiff bears burden to establish jurisdiction)
Ziegler v. Indian River Cnty., 64 F.3d 470 (9th Cir. 1995) (plaintiff bears burden to establish personal jurisdiction)
Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797 (9th Cir. 2004) (minimum-contacts standard for personal jurisdiction)
Menken v. Emm, 503 F.3d 1050 (9th Cir. 2007) (distinguishes general presence from specific jurisdiction; forum-contact requirements)
Axiom Foods, Inc. v. Acerchem Int’l, Inc., 874 F.3d 1064 (9th Cir. 2017) (sets three-part test for specific jurisdiction and purposeful-direction test for tort claims)
TeleVideo Sys., Inc. v. Heidenthal, 826 F.2d 915 (9th Cir. 1987) (on default, allegations are taken as true except those relating to amount of damages)
Camacho v. Bridgeport Fin., Inc., 523 F.3d 973 (9th Cir. 2008) (fee applicants must produce evidence that requested rates are in line with prevailing community rates)
S.E.C. v. Ross, 504 F.3d 1130 (9th Cir. 2007) (distinguishes personal jurisdiction from venue)