MA SHUN BELL, APPELLANT, v. WEINSTOCK, FRIEDMAN & FRIEDMAN, P.A., et al., APPELLEES.
No. 23-CV-0413
DISTRICT OF COLUMBIA COURT OF APPEALS
Decided June 5, 2025
Nоtice: This opinion is subject to formal revision before publication in the Atlantic and Maryland Reporters. Users are requested to notify the Clerk of the Court of any formal errors so that corrections may be made before the bound volumes go to press.
Radi Dennis for appellant.
David M. Ross, with whom Kevin P. Farrell and Daniel R. Coffman were on the brief, for appellees.
Before HOWARD and SHANKER, Associate Judges, and THOMPSON, Senior Judge.
THOMPSON, Senior Judge: This matter returns to the court after a remand.1 Appellant, Ma Shun Bell, seeks reversal of an order of the Superior Court dismissing her second amended complaint (the complaint) against defendant/appellee Friedman, Framme & Thrush (a law firm formerly known as Weinstock, Friedman & Friedman) (FFT). In essence, the various counts of Ms. Bell‘s complaint allege that FFT committed an unfair trade practice and an abuse of process by filing a lawsuit on behalf of First Investors Servicing Corporation (FISC)—FFT‘s client and Ms. Bell‘s creditor—to recover an alleged deficiency debt that FFT knew could not be lawfully recovered because of procedural defects in the vehicle-repossession process.2 The Superior Court dismissed each of the five counts of the complaint, ruling that the complaint failed to allege the elements of a Uniform Commercial Code (UCC)3 violation; that by virtue of its role as FISC‘s “litigation attorneys,” FFT was “immune from suit under the [Consumer Protection Procedures Act (CPPA)]4 and, by extension, [the D.C. Automobile Financing and Repossession Act (AFRA)]“;5 that the complaint does not “articulate[] how [FFT‘s] conduct violated the [Debt Collection Law
(DCL)]“;6 that the complaint failed to state a claim for abuse of process; and that in any event Ms. Bell‘s claims are barred by res judicata based on a Small Claims Court judgment in favor of FISC, with which, the court found, FFT was in privity.
For the reasons that follow, we conclude that Ms. Bell‘s DCL сause of action may proceed, but that her other causes of action were properly dismissed. We therefore affirm in part, reverse in part, and remand for further proceedings.
I.
In 2012, Ms. Bell purchased a car from a car dealership via an installment sales contract. See Bell v. First Invs. Servicing Corp., 256 A.3d 246, 249 (D.C. 2021) (Bell I). Subsequently, the right to collect on the
In Small Claims Court, Ms. Bell appeared pro se. See Bell III, 285 A.3d at 508.7 After court-sponsored mediation, she signed a “Stipulation/Settlement” in which she agreed to pay FISC $8,271.41 in monthly installments, with the condition that if she defaulted on the agreement, FISC could apply for entry of judgment for the remaining balance. Id. at 507. Ms. Bell eventually defaulted on the agreement, FFT filed FISC‘s Motion to Enter Judgment Pursuant to Stipulation of Settlement, and the Superior Court entered a judgment in favor of FISC. According to Ms. Bell‘s brief, the judgment amount was fully paid through garnishment of Ms. Bell‘s wages.
In the wake of the foregoing, Ms. Bell, through counsel, filed putative class-action lawsuits against both FISC and FFT. Bell III, 285 A.3d at 506-07. She recited essentially the same claims in each suit, alleging that the defendants violated AFRA, the CPPA, the UCC, and the DCL and abused process. In Bell I, as pertinent here, this court held that Ms. Bell‘s claims against FISC (other than the
DCL claim, which had been properly dismissed on a separate ground) were barred by res judicata to the extent that they rested on a claim that FISC was not entitled to recover the deficiency balance awarded to it under the Small Claims Court judgment. See 256 A.3d at 258. We remanded the case for further proceedings as to the non-barred claims, id. at 259 (аnd that case, which is against FISC only, remains pending in Superior Court).
In Ms. Bell‘s suit against FFT in the instant case, the Superior Court initially ruled that res judicata precluded Ms. Bell from asserting any claim against FFT that she could not assert against FISC because FFT, solely by virtue of its role as FISC‘s attorney during the Small Claims litigation and settlement proceedings, was in privity with FISC. See Bell III, 285 A.3d at 507-09. This court reversed, holding that the attorney-client relationship in itself is not sufficient to create privity between lawyer and client for purposes of res judicata. Id. at 511 (“[T]he required mutuality of interests will not exist in every circumstance.“). We remanded the case to the Superior Court to analyze the mutuality of FISC‘s and FFT‘s legal interests. Id. at 511-12. We “ma[d]e no determination regarding whether Ms. Bell‘s claims m[ight] be dismissed on alternative grounds.” Id.
On remand, the Superior Court again concluded that there was privity between FISC and FFT because of the contingency-fee arrangement between the two entities, which gave them “a mutual interest in reсovery of the deficiency from Ms. Bell” that supported the application of res judicata. The court granted FFT‘s motion to dismiss, ruling in addition that the UCC claim does not lie against FFT because it was not a secured party; that Ms. Bell‘s
This appeal followed.
II.
“A complaint should be dismissed under [Super. Ct. Civ.] Rule 12(b)(6) if it does not satisfy the pleading standard in [Super. Ct. Civ.] Rule 8(a)[,]” which “requires a pleading to contain a ‘short and plain statement of the claim showing that the pleader is entitled to relief.‘” Potomac Dev. Corp. v. District of Columbia, 28 A.3d 531, 543 (D.C. 2011) (quoting
This court reviews de novo dismissal of a complaint under Rule 12(b)(6) for failure to state a claim on which relief can be granted. Potomac Dev. Corp., 28 A.3d at 543. We also review de novo whether a claim is barred by res judicata. See U.S. Bank, N.A. v. 1905 2nd Street NE, LLC, 85 A.3d 1284, 1287 (D.C. 2014). We likewise review de novo the statutory-interpretation issue of whether a defendant is entitled to the protection of a statutory еxemption. See Thorne v. United States, 55 A.3d 873, 877 (D.C. 2012).
III.
We address in turn the various grounds upon which the Superior Court dismissed Ms. Bell‘s complaint.
A. AFRA
In the first count of her complaint (For Violations of the District of Columbia Automobile Financing and Repossession Act,
intended repossession of the Vehicle” and “was never notified that the Vehicle had been repossessed” or “notified where she would be able to collect her personal belongings that were in the Vehicle at the time of repossession“), or they attribute omissions to “the creditor” rather than to FFT (“[t]he creditor did not notify the District of Columbia Metropolitan Police Department after taking the vehicle.“). Such formulations in a complaint against FFT do not satisfy the Iqbal/Twombly pleading requirements.9 They fall short of “rais[ing] a reasonable expectation that discovery will reveal evidence” supporting FFT‘s involvement in AFRA violations. Twombly, 550 U.S. at 556.
In short, we agree with FFT and with the Superior Court that Ms. Bell‘s failure to allege that FFT was actually involved in or responsible for the
repossession or sale of her car or the issuance of improper notice(s) rendered the first count of the complaint insufficient to survive dismissal under Superior Court Civ. R. 12(b)(6) for failure to state a claim against FFT.10
B. UCC Article 9 Claims
In her second cause of action (U.C.C. Article 9 et seq.), Ms. Bell alleges that FFT, in violation of the requirements of U.C.C. Article 9, “did not provide ‘reasonably authenticated notice’ of sale of the [v]ehicle prior to collecting the alleged deficiency debt[] of Ms. Bell[,]” “did not provide ‘reasonably authenticated notice’ of [Ms. Bell‘s] redemption rights... prior to collecting the alleged deficiency debt[,]” and “did not provide all the required pre and post-sale notices
prior to collecting the deficiency debt[].”11 Ms. Bell also alleges
Ms. Bell‘s UCC claims are more specific than her AFRA claims, but the Superior Court did not err in dismissing the claims. The notice provisions of Article 9, Part 6 of the UCC apply to a “secured party” who disposes of collateral following a borrower‘s default. See
that a secondary obligor takes on the duties of a secured party if the secondary obligor (1) receives an assignment of the secured obligation; (2) receives a transfer of collateral and agrees to accept the rights and assume the duties of the secured party; or (3) is subrogated to the rights of a secured party). The complaint does not allege that a security interest in Ms. Bell‘s vehicle was created in FFT‘s favor or that Ms. Bell‘s account was sold or assigned to FFT. Even if we assume that FFT could be liable for damages as a non-secured-party “person” under
As to Ms. Bell‘s claim that FFT did not act in good faith, the official commentary to section 1-304 of the UCC and
C. CPPA Claims
Ms. Bell‘s third cause of action (“District of Columbia Consumer Procedures and Protections Act,
Citing
consumer-protection agency may not “apply the provisions of [
Judgment—fall comfortably within the exemption. Accordingly, we uphold the dismissal of Ms. Bell‘s CPPA claims against FFT.16
D. Debt Collection Law
1. Satisfaction of the pleading standard
The fourth count of Ms. Bell‘s complaint (District of Columbia Debt Collection Law) begins by reciting various prohibitions set forth in
We agree with FFT and with the Superior Court that some aspects of the fourth count do “not explain how [FFT‘s] conduct satisfied the elements of any of [the
paraphrased] provisions [of the DCL].” While the fourth count asserts that FFT communicated with Ms. Bell while knowing she was represented by counsel, it does not identify when these allegedly improper communications occurred (and the general allegations of the complaint state that FFT communicated with Ms. Bell when she was proceeding pro se in the Small Claims Court). As to FFT‘s allegedly “filing false affidavits purporting to verify a debt,” the affidavit attached to the Small Claims сomplaint avers that the debt amount described in the other attachments to the complaint was “a just and true statement of the amount owing . . . exclusive of all set-offs and just grounds for defense.” We read that statement to mean that the amount stated was the true debt amount, not including (i.e., not reflecting) any amounts to be deducted as set-offs or on account of just defenses. Cf. Ethos Techs., Inc. v. RealNetworks, Inc., 462 F. Supp. 2d 131, 143 (D. Mass. 2006) (“The plain meaning of the phrase ‘exclusive of’ is ‘[n]ot including: besides.‘” (brackets in original) (quoting Webster‘s II New College Dictionary 399 (3d ed. 2005))). Thus, with the “exclusive of all set-offs and just grounds for defense” phrasing—which seems to acknowledge the possibility of affirmative defenses such as lack of statutorily mandated notice—the affidavit cannot be said to be false (i.e., the allegation that it is false is not plausible).17
Further, in “allegations common to all causes of action,” the complaint alleges
However, “liberally interpreted in favor of the pleader[,]”18 and in conjunction with the “Allegations Common to All Causes of Action,” we are satisfied that other allegations of the fourth count “nudge[] [Ms. Bell‘s DCL]
claims across the line from conceivable to plausible.”19 Tingling-Clemmons v. District of Columbia, 133 A.3d 241, 246 (D.C. 2016) (first alteration in original) (internal quotation marks omitted). Ms. Bell‘s allegations are sufficient to state a claim that FFT, by filing suit in the Small Claims Court on behalf of FISC, “attempt[ed] to collect a[] charge, fee, or expense incidental to the principal obligation [that was not]... legally chargeable to the consumer.”
Also sufficient to state a claim is Ms. Bell‘s allegation that the “creditor did not notify the District of Columbia Metropolitan Police Department after taking the vehicle,” an allegation that implicates
FFT argues that even if Ms. Bell sufficiently pled the other elements of her DCL claim, she “failed to plead facts to support an inference that [FFT] acted willfully, as was required by the DCL in 2017 when [FFT] represented FISC in its
lawsuit against [Ms.] Bell.”21 The background of this argument is, as FFT‘s brief notes, that the Council amended the DCL in 2022 by deleting subparagraph (j), which had provided that “[p]roof, by substantial evidence, that a debt collector has wil[l]fully violated any provision of the [DCL] shall subject such debt collector to liability to any person affected by such violation for all damages proximately caused by the violation.”
The repeal does not apply retroactively. We presume that “legislation that affects substantive rights“—i.e., that “changes the legal consequences of acts completed before its effective date“—will “operate only prospectively.” Lacek v. Wash. Hosp. Ctr. Corp., 978 A.2d 1194, 1197 (D.C. 2009) (quoting Landgraf v. USI Film Prods., 511 U.S. 244, 269 n.23 (1994)).22 The 2022 amendment did not merely “alter[] the procedure by which a [DCL plaintiff] may obtain [her] objectives,” Holzsager v. D.C. Alcoholic Beverage Control Bd., 979 A.2d 52, 58 (D.C. 2009) (internal quotation marks omitted), but also “increase[d] [a debt collector‘s] liability for past conduct,” id. at 57 (internal quotation marks omitted), making a debt collector potentially liable for damages for conduct that was committed inadvertently or negligently but not willfully. We readily conclude that the 2022 amendment effected a substantive rather than procedural change and therefore may not be applied retroactively in this case, which is based on FFT‘s alleged pre-2022 conduct. We thus agree with FFT that Ms. Bell must prove willfulness to prevail on her DCL claim for damages.
However, Ms. Bell‘s compliant sought not only damages but also “a declaratory judgment that [FFT has] violated the . . . DCL and injunctive relief preventing continued collection of barred deficiency debt[.]” That relief would be available to Ms. Bell if she prevails even if she cannot show that FFT acted willfully in (allegedly) violating the DCL.23 For that reason,
2. Res judicata
Now that we have determined that Ms. Bell has plausibly alleged a violation of the DCL, we must consider a remaining issue: whether her DCL claims against FFT are barred by res judicata. As we have explained, “[i]n determining whether res judicata applies, [w]e consider (1) whether the claim was adjudicated finally in the first action [here, the Small Claims action]; (2) whether the present claim is the same as the claim which was raised or which might have been raised in the prior proceeding; and (3) whether the party against whom the plea is asserted was a party or in privity with a party in the prior case.” Price v. Indep. Fed. Sav. Bank, 110 A.3d 567, 571 (D.C. 2015) (second alteration in original) (quoting Calomiris v. Calomiris, 3 A.3d 1186, 1190 (D.C. 2010)). The remand we ordered in Bell III was for the Superior Court to focus on the third element of res judicata, privity.
Courts have acknowledged that “[t]he term ‘privity’ is an elusive concept, without any precise definition of general applicability.” Jefferson Sch. of Soc. Sci. v. Subversive Activities Control Bd., 331 F.2d 76, 83 (D.C. Cir. 1963); see also Buechel v. Bain, 766 N.E.2d 914, 920 (N.Y. 2001) (“[P]rivity is an amorphous concept not easy of application . . . .” (internal quotation marks omitted)). This case amply demonstrates the difficulty of applying the concept. We also nоte that courts have reached conflicting conclusions about whether lawyers who successfully represented creditor clients in consumer-debt collection actions have the benefit of res judicata when the consumers against whom judgments were entered in the debt-collection actions sue the creditors’ lawyers alleging deceptive conduct in pursuit of debt collection.25 But in this case
The Superior Court concluded on remand that FFT and FISC were in privity because of their contingent-fee compensation agreement, which FFT provided to the court.26 The court reasoned:
Here, FISC and [FFT] had a mutual interest in recovery of the deficiency from Ms. Bell. The representation agreement between FISC and [FFT] stipulated that FISC would assign delinquent accounts to [FFT] and [FFT] would be entitled to a 30% commission on any sums recovered. [FFT‘s] commission is not contingent upon [FFT] filing a suit on FISC‘s behalf . . . The representation agreement unites FISC‘s and [FFT‘s] interests more than even in a standard contingency agreement. Moreover, where [FFT] did bring a suit against buyers, FISC‘s sought-after recovery was purely monetary, meaning that FISC did not have any interest in recovery which [FFT] did not share. [FFT‘s] and FISC‘s purely monetary interests combined with their enhanced contingency representation agreement establishes a mutuality of interests with respect to Ms. Bell‘s claims.
A litmus test for mutuality is whether a litigant would have been bound by a prior decision which reached the opposite result. Applied here, the question is whether, if FISC‘s suit against Ms. Bell in 2017 to recover the deficiency was unsuccessful, [FFT] would have been able to assert its own claim against Ms. Bell to recover the deficiency. It would not. [FFT‘s] property interest in recovering a deficiency against Ms. Bell for her unpaid car loan was fully represented by FISC. Had [FFT] tried to bring a second claim as party plaintiff after FISC was unsuccessful, Ms. Bell would have been entitled to raise a defense of res judicata. This further confirms the mutuality of FISC‘s and [FFT‘s] interest in the recovery of a deficiency.
Because privity exists between [FFT] and FISC with respect to Ms. Bell‘s claims, [FFT] is entitled to assert res judicata on the same grounds as FISC did in Bell I.
Thus, the Superior Court reasoned that FFT and FISC were in privity because they had “a shared economic interest in the outcome of the litigation“—specifically, “a mutual interest in recovery of the deficiency from Ms. Bell.”
We conclude that the Superior Court departed from the remand instructions by focusing on FFT‘s and FISC‘s mutual interest in recovery of funds from Ms. Bell rather than on whether they had a mutual interest in the deficiency debt itself, which was “the subject matter of the [Small Claims] case.” Patton, 746 A.2d at 870 (internal quotation marks omitted). The record that was before the Superior Court established that as between FFT and FISC, only FISC had a “legal right [with] respect to [that] subject matter.” Id. Despite the Superior Court‘s reference to FISC‘s “assign[ment] [of] delinquent accounts to [FFT]“—by which the Superior Court seems to have meant the referral of accounts to FFT, rather than a true assignment of accounts27—the contingent-fee agreement that is in the record indicates explicitly that FFT was granted no legal interest in FISC‘s accounts. The agreement states that:
All Accounts placed . . . with Contractor [i.e., FFT] are, and shall remain, the exclusive property of the FISC Entities. FISC shall place Accounts with Contractor at its sole discretion. . . . Contractor shall acquire no right, title, or interest in any Accounts placed with Contractor.”
Similarly, the agreement states that:
FISC shall have the absolute right to recall any Account placed with Contractor at any time, for any reason, in its sole discretion, with or without cause. . . . Contractor shall not be entitled to any . . . compensation . . . in respect of a Recalled Account on or after the date that such Account constitutes a Recalled Account.
The agreement also establishes that an account can be recalled in the middle of litigation. Taken together, these provisions of the FFT/FISC compensation agreement indicate that FFT had no legal interest in the debt; rather, FFT had a legal interest that came into play only after there was a recovery on the debt. Thus, FISC and FFT had different legal interests in respect to the subject matter of the Small Claim action.28
We shall also briefly discuss why Ms. Bell‘s DCL claims against FFT are not barred by the other branch of res judicata: issue preclusion, or collateral estoppel. See Taylor v. Sturgell, 553 U.S. 880, 892 (2008) (explaining that the term “res judicata” can be used to refer to both claim preclusion and issue preclusion/collateral estoppel). We have considered this issue because the lack of privity between FFT and FISC would not render the doctrine of issue preclusion inapplicable. “[T]his jurisdiction permits a defendant in an action to invoke collateral estoppel based on a prior determination rejecting a plaintiff‘s claim against other parties, even in thе absence of privity.” Walker v. FedEx Off. & Print Servs., 123 A.3d 160, 165 (D.C. 2015); see also Carr, 701 A.2d at 1076 (“[A] stranger to the first action may invoke issue preclusion against a party to that action. Hence the . . . defendants, while not privy to the prior dispute, are not thereby necessarily prevented from asserting defensive ‘non-mutual’ collateral estoppel.” (citation omitted)).
Collateral estoppel, or issue preclusion, “may be invoked defensively by a defendant who was not a party to the original proceedings, to prevent a plaintiff from relitigating an issue that the plaintiff had previously litigated unsuccessfully.” Walker, 123 A.3d at 164. We have cautioned, however, that issue preclusion applies to bar relitigation of an issue of fact or law only when “the issue is actually litigated.” Id. (internal quotation marks omitted)). Here, as Ms. Bell emphasizes, the Small Claims Court judgment was a consent judgment, entered pursuant to the terms of the settlement/stipulation between FISC and Ms. Bell, raising the question of whether the issue of FISC‘s entitlement to reсover the deficiency debt was actually litigated. Courts have held that whether a consent judgment satisfies the “actually litigated” element depends on the parties’ intent as manifested by the record. See Richardson v. Ala. State Bd. of Educ., 935 F.2d 1240, 1245 (11th Cir. 1991) (“[T]he nature of consent decrees forces a twist in th[e] [issue-preclusion] analysis because the second requirement, actual litigation, is always missing when cases are settled. The proper analysis . . . is whether the parties specifically agreed to preclude a given issue.” (internal quotation marks and citations omitted).29 “[T]he central inquiry
The Small Claims Court consent judgment makes no factual findings other than declaring that Ms. Bell was obligated to pay FISC the balance of the claimed deficienсy debt. Further, the wider record in the Small Claims action does not permit an inference that Ms. Bell intended to waive any defenses she might have to the debt-collection action. She moved to vacate the judgment, and in her reply to FISC‘s opposition to the Motion to Vacate specifically asserted that she signed the stipulation “unaware of any purported waiver.” On this record, we cannot conclude, for purposes of issue preclusion, that the issue of whether the amount of the deficiency debt was falsely represented or overstated was actually litigated and resolved in FISC‘s favor such that the claim is barred against FFT. Accordingly, Ms. Bell‘s DCL claims are not barred by collateral estoppel.
E. Abuse of Process
The fifth and final count of Ms. Bell‘s complaint alleges that FFT instituted a lawsuit (the Small Claims Court action) for the purpose of coercing Ms. Bell to pay an alleged debt that was not owed and in order to convert a bаrred deficiency debt to an enforceable judgment; abused or perverted the judicial process by making false claims and filing fraudulent verifications of debt to obtain a settlement to pay a debt that was not owed; and abused the judicial process by filing a fraudulent affidavit stating that the amount alleged in the Small Claims Court complaint was a true statement of the amount owed.
In our jurisdiction, the test for determining when a cause of action for abuse of process will lie is whether “the process has been used to accomplish some end which is without the regular purview of the process, or which compels the party against whom it is used to do some collateral thing which he could not legally and regularly be required to do.” Morowitz v. Marvel, 423 A.2d 196, 198 (D.C. 1980) (quoting Jacobson v. Thrifty Paper Boxes, Inc., 230 A.2d 710, 711 (D.C. 1967)). That a party may have an ulterior motive, such as coercion, for pursuing litigation that is within the regular purview of the process is not sufficient to sustain a claim for abuse of process. See Nolan v. Allstate Home Equip. Co., 149 A.2d 426, 430 (D.C. 1959) (“The mere bringing of suit even with an ulterior motive of coercion does not of itself constitute malicious abuse of process.“); Geier v. Jordan, 107 A.2d 440, 441 (D.C. 1954) (complaint failed to state a claim for malicious abuse of process where it “alleged only a wrongful purpose” and “failed entirely to charge any act on the part of appellee by which the judicial process was perverted“). To state a claim for abuse of process, “in addition to ulterior motive, one must allege and prove that there has been a perversion of the judicial process and achievement of some end not contemplated in the regular prosecution of the charge,” Morowitz, 423 A.2d at 198; i.e., a “perversion of the court process to accomplish an end which the process was not intended to bring about,” Hall v. Hollywood Credit Clothing Co., 147 A.2d 866, 868 (D.C. 1959). Thus, “knowingly br[inging] suit on an unfounded claim . . . by itself is not an abuse of process.”30 Hall, 147 A.2d at 868. But, for example, pursuing an “attachment upon a judgment at a time when there was no judgment outstanding was an abuse of process, because appellee thereby forced appellant to do something which it could not otherwise legally and regularly compel her to do.” Id. (footnote omitted).
We agree with the Superior Court that Ms. Bell‘s complaint failed to state a claim for abuse of process. As the Superior Court aptly put it, the complaint does not allege that FFT sought to coerce Ms. Bell into “tak[ing] some action other than paying FISC money.” Ms. Bell‘s allegation that FFT filed a lawsuit against her to collect a deficiency debt (albeit a debt that she contends she did not owe) is in effect an acknowledgement that FFT filed the Small Claims action for its intended purpose, rather than “for an immediate purpose other than that which it was designed to accomplish.” Restatement (Second) of Torts § 682 cmt. b (Am. L. Inst. 1977); see also Martin v. Trevino, 578 S.W.2d 763, 769 (Tex. Civ. App. 1978).
F. Conclusion
For the foregoing reasons, we reverse that portion of the Superior Court‘s order dismissing the DCL count of Ms. Bell‘s complaint, but otherwise affirm the judgment of dismissal. The case is remanded for further proceedings. It is
So ordered.
Notes
Within one (1) hour after repossession of a motor vehicle, the individual who performed the repossession shall notify the Metropolitan Police Department of the repossession and shall provide the following data: (a) The name and address of the registered owner; (b) The name and address of the repossessor; (c) The name and address of the holder; (d) The tag number and description of the vehicle; (e) The location from which the vehicle was repossessed; (f) Where the vehicle is located; (g) The date and time of repossession; and (h) Other information required by the Metropolitan Police Department.