Howard

INTRODUCTION

Plaintiff Richard Howard sued Defendant GC Services, Inc., an entity that provides debt collection services for Los Angeles County, alleging that defendant had sent him a letter that falsely stated plaintiff owed Los Angeles County Superior Court unadjudicated bail in connection with a red-light camera citation and demanded payment. Plaintiff alleged that various representations in the letter were false and misleading and did not reflect the policies of the Los Angeles Superior Court. Plaintiff appeals from the trial court’s order denying his motion to certify a class of all California residents who had received letters from the defendant containing similar representations. The trial court ruled that plaintiff failed to meet his burden of demonstrating that common issues predominated, that his claims were typical of the class, and that his attorney was adequate to serve as class counsel. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. Defendant’s Role in Los Angeles’ Traffic Enforcement Camera System In 2007 and 2008, the County of Los Angeles contracted with a third-party vendor to operate automated traffic enforcement cameras. These cameras photographed…