People v. Super. Ct. (Credit One Bank)

FACTS

In March 2021, the district attorneys of Riverside, San Diego, Los Angeles, and

Santa Clara counties, on behalf of the People, sued Credit One for violating California’s

Rosenthal Fair Debt Collection Practices Act (Civ. Code, § 1788 et seq., Rosenthal Act)

and Unfair Competition Law (Bus. & Prof. Code, § 17200 et seq., UCL). The People

allege Credit One, either directly or through vendors, engaged in debt collection activities

“that involve unreasonably frequent and harassing phone call patterns and conduct.” The

lawsuit seeks injunctive relief, civil penalties, restitution to victims, costs of suit, and

other equitable relief.

Credit One propounded written discovery, and the People responded. In April

2023, the People served written objections and responses to 14 requests for production of

documents, 33 special interrogatories, and a set of form interrogatories. The People’s

production included thousands of pages of documents. In March 2024, the People served

objections and responses to 18 requests for admissions and another response to form

interrogatories.

3 In January 2024, Credit One noticed the deposition of the People’s PMQ. The

notice identified 25…