Taylor v. Premier Portfolio Group, 2:18-cv-00236

Taylor received voicemail(s) and calls in Feb 2017 from Premier (domain linked to Asset and Michael Evans) about a purported "bad check."
Voicemail on Feb 14 said only documentation and to press zero; later messages on Feb 20–21 mentioned a "bad check" but did not identify the caller as a debt collector.
Defendants also called Taylor’s workplace and told her boss they were trying to contact her "because of a bad check," without her consent.
Taylor sued under the Fair Debt Collection Practices Act (FDCPA), alleging four violations: failure to meaningfully disclose identity, failure to disclose debt-collection purpose, impermissible third-party communication, and false representation about a bad check.
Default was entered against Asset, Michael Evans, and Premier; Taylor moved for default judgment seeking statutory damages ($1,000), costs ($424), and attorney’s fees ($5,162.50).
The court granted default judgment, finding the complaint’s well-pleaded allegations establish liability and awarding a total of $6,586.50.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether voicemail(s) failed to disclose caller identity and purpose (§1692d/§1692e(11))	Taylor: voicemails did not identify caller as debt collector or state purpose; violated disclosure rules	Defaulted — no opposing factual/legal rebuttal	Court: Taken as true on default; messages violated FDCPA disclosure requirements
Whether voicemails/communications contained false or misleading statements about the debt (§1692e)	Taylor: defendants falsely stated debt existence ("bad check") though none existed	Defaulted — no rebuttal	Court: Allegations deemed true on default; false representation actionable under FDCPA
Whether defendants impermissibly communicated with a third party about the debt (§1692c/§1692b)	Taylor: defendants told her boss about a "bad check," not limited to location information, thus violated statute	Defaulted — no rebuttal	Court: Conduct violated FDCPA restrictions on third-party communications
Availability and amount of statutory damages, costs, and attorney's fees (§1692k)	Taylor: Entitled to up to $1,000 statutory damages plus costs/fees; detailed billing submitted	Defaulted — no opposition to amounts beyond scrutiny of reasonableness	Court: Awarded $1,000 statutory damages, $424 costs, and $5,162.50 attorney’s fees (total $6,586.50)

TeleVideo Sys., Inc. v. Heidenthal, 826 F.2d 915 (9th Cir.) (defaulted party deemed to have admitted well-pleaded allegations)
Fair Hous. of Marin v. Combs, 285 F.3d 899 (9th Cir.) (court need not make detailed factual findings on default judgment)
Adriana Int’l Corp. v. Thoeren, 913 F.2d 1406 (9th Cir.) (same—default judgment standards)
Smith v. Levine Leichtman Capital Partners, Inc., 723 F. Supp. 2d 1205 (N.D. Cal.) (standards for officer liability under FDCPA)
Berg v. Merchants Assoc. Collection Div., Inc., 586 F. Supp. 2d 1336 (S.D. Fla.) (voicemail messages are communications subject to FDCPA disclosure rules)
Lensch v. Armada Corp., 795 F. Supp. 2d 1180 (W.D. Wash.) (voicemails must conform to §1692e(11) disclosure requirements)
Moritz v. Daniel N. Gordon, P.C., 895 F. Supp. 2d 1097 (W.D. Wash.) (meaningful disclosure requires name, capacity, and not misleading purpose of call)
Guerrero v. RJM Acquisitions LLC, 499 F.3d 926 (9th Cir.) ("least sophisticated debtor" standard for FDCPA harassment analysis)
Tourgeman v. Collins Fin. Servs., Inc., 755 F.3d 1109 (9th Cir.) (materiality requirement for false or misleading representations under FDCPA)
Donohue v. Quick Collect, Inc., 592 F.3d 1027 (9th Cir.) (defining genuinely misleading vs. technical falsehoods for FDCPA materiality)