Jeannie Palmer v. HSBC Bank, USA, Na

facts sought exist; and (3) the sought after facts are essential to oppose summary

judgment.” Stevens v. Corelogic, Inc., 899 F.3d 666, 678 (9th Cir. 2018) (citation

omitted). Mrs. Palmer failed to meet this burden because she merely speculated

that the sought-after testimony and documents might contradict the evidence

already before the district court. See id. (“[F]or purposes of a Rule 56(d) request,

the evidence sought must be more than ‘the object of pure speculation.’”) (quoting

California v. Campbell, 138 F.3d 772, 779–80 (9th Cir. 1998)).

3. The district court properly granted summary judgment to HSBC because

the undisputed evidence established that HSBC lawfully accessed Mr. Palmer’s

information solely in order to make a firm offer of credit. See Nayab, 942 F.3d at

488 (The FCRA “allows a third-party to obtain a consumer’s credit report . . . ‘if

the transaction consists of a firm offer of credit’”) (quoting 15 U.S.C.

§ 1681b(a)(3)(A)). Here, HSBC mailed Mr. Palmer a “‘prescreened’ offer of

credit” to apply for HSBC’s Gold Mastercard. HSBC informed Mr. Palmer that

3 the offer was “based on information in your credit report indicating that you meet

certain…