Escamilla Avina v. Patenaude & Felix, APC

CourtDistrict Court, S.D. California
DecidedMarch 9, 2021
Docket3:20-cv-00166
StatusUnknown

This text of Escamilla Avina v. Patenaude & Felix, APC (Escamilla Avina v. Patenaude & Felix, APC) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Escamilla Avina v. Patenaude & Felix, APC, (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 JORGE ESCAMILLA AVINA, on Case No. 20-cv-00166-BAS-MDD 11 behalf of himself and all others similarly situated, ORDER: 12 Plaintiff, (1) GRANTING IN PART AND 13 DENYING IN PART DEFENDANT v. PATENAUDE & FELIX, APC AND 14 CREDIT CORP. SOLUTIONS, PATENAUDE & FELIX, APC; CREDIT INC.’S MOTION TO DISMISS 15 CORP. SOLUTIONS, INC.; THOMAS (ECF No. 16); FLYNN, 16 AND Defendants. 17 (2) DENYING DEFENDANT THOMAS FLYNN’S MOTION TO DISMISS 18 (ECF No. 17) 19 20 Before the Court are two Motions to Dismiss filed by Defendants Patenaude & Felix, 21 APC and Credit Corp. Solutions, Inc. (the “Entity Defendants”) and individual Defendant 22 Thomas Flynn. (ECF Nos. 16, 17.) Plaintiff opposes both Motions (ECF Nos. 19, 20) and 23 Defendants reply. (ECF Nos. 21, 22.) The Court finds both Motions suitable for 24 determination on the papers submitted and without oral argument. See Fed. R. Civ. P. 25 78(b); CivLR 7.1(d)(1). For the reasons stated below, the Court GRANTS IN PART and 26 DENIES IN PART the Entity Defendants’ Motion and DENIES Defendant Flynn’s 27 Motion. 28 1 I. FACTUAL BACKGROUND 2 Plaintiff Jorge Escamilla Avina (“Plaintiff”) commenced this action on January 24, 3 2020. (ECF No. 1.) Plaintiff filed the operative First Amended Complaint (“FAC”) on 4 April 14, 2020. (ECF No. 9.) 5 This action stems from Plaintiff’s alleged default on a consumer credit card account 6 in 2016. (FAC ¶ 13.) The original creditor, Synchrony Bank, assigned the debt to 7 Defendant Credit Corp. Solutions, Inc. (“CCS”). (Id.) CCS retained Defendant Patenaude 8 & Felix, APC (“P&F”), which then filed a debt collection lawsuit in state court on June 11, 9 2019. (Id. at 14.) P&F hired Defendant Flynn as a private process server to serve the 10 summons and complaint on Plaintiff. (Id.) 11 On July 12, 2019, Flynn filed a proof of service with the state court representing that 12 on July 1, 2019, Flynn completed personal service upon Plaintiff at his residence. (FAC ¶ 13 15.) However, Plaintiff states that he was not home at this time and therefore could not 14 have been personally served. (Id.) Consequently, Plaintiff filed a motion to quash service 15 and attached a timecard showing that he was working at the time of the alleged personal 16 service. (Id. ¶ 16.) In response, the Entity Defendants sent Flynn to re-serve the summons 17 and complaint; he again filed a proof of service indicating that he personally served 18 Plaintiff at his residence on November 9, 2019, mooting the motion to quash. (Id.) Again, 19 however, Plaintiff alleges he was not home at this time and claims that his mother “found 20 CCS’ lawsuit lying on the front porch[.]” (Id.) Plaintiff filed a second motion to quash, 21 which was again mooted by Defendants’ request to dismiss the action without prejudice on 22 January 2, 2020. (Id. ¶ 17.) 23 Plaintiff states that Flynn’s filing of false proofs of service violates the Fair Debt 24 Collection Practices Act (“FDCPA”), 15 U.S.C. §§ 1692, et seq. (FAC ¶ 19.) Specifically, 25 Plaintiff claims that Flynn’s actions: (1) constitute conduct the natural consequence of 26 which is to harass the debtor in connection with the collection of a debt (15 U.S.C. § 27 1692d); (2) falsely represent the legal status of the debt and use false representations and 28 1 deceptive means in an attempt to collect a debt (id. § 1692e(2)(A), 1692e(10)); and (3) use 2 unfair and unconscionable means in an attempt to collect a debt (id. § 1692f). (FAC ¶ 27.) 3 In addition, Plaintiff states that CCS and P&F are vicariously liable for Flynn’s 4 violations because they knew or should have known that Flynn regularly conducts “sewer 5 service”1 on plaintiffs yet continue to use him to serve CCS’s debt collection lawsuits and 6 that their compensation arrangement with Flynn incentivizes his dishonest conduct. (Id. 7 ¶¶ 29–35.) 8 In support of Plaintiff’s first contention, the FAC includes data reflecting Flynn’s 9 “unrealistically high percentage” of lawsuits purportedly personally served on defendants 10 in debt collection cases, the equally high number of nonresponsive defendants who were 11 supposedly personally served, and Flynn’s “inexplicable descriptions” of people allegedly 12 personally served. (FAC ¶¶ 33–34.) Plaintiff claims that this data has “at all times been 13 readily available to [P&F] and CCS,” but that they nonetheless “continue to exclusively 14 use Flynn to serve CCS’ debt collection lawsuits,” indicating that both the Entity 15 Defendants “willfully ignored” and “knowingly profit off” Flynn’s fraudulent conduct by 16 continuing to use his services. (Id.) As to the second allegation, Plaintiff claims that 17 because P&F and CCS pay Flynn only for completed service, “Flynn is incentivized . . . to 18 complete service on the first attempt by either claiming ‘personal service’ or by claiming 19 the address is not valid for service.” (Id. ¶ 34.) 20 Plaintiff brings the action on behalf of himself and a class of all persons: (1) residing 21 in California; (2) against whom Defendants “jointly filed proofs of ‘personal service’ of 22 process in the San Diego County Superior Court of the State of California . . . in debt 23 collection lawsuits in which the person was not personally served with process”; and (3) in 24 an attempt to collect personal, family, or household debts from January 24, 2019 to the date 25 of class certification. (Id. ¶ 37.)

26 1 “Sewer service” occurs when the defendant “fail[s] to serve a debtor and fil[es] a fraudulent 27 affidavit attesting to service so that when the debtor later fails to appear in court, a default judgment can be entered against them.” Holmes v. Elec. Document Processing, Inc., 966 F. Supp. 2d 925, 929 (N.D. 28 1 II. LEGAL STANDARD 2 A motion to dismiss pursuant to Rule 12(b)(6) of the Federal Rules of Civil 3 Procedure tests the legal sufficiency of the claims asserted in the complaint. Fed. R. Civ. 4 P. 12(b)(6); Navarro v. Block, 250 F.3d 729, 731 (9th Cir. 2001). The court must accept 5 all factual allegations pleaded in the complaint as true and must construe them and draw all 6 reasonable inferences from them in favor of the nonmoving party. Cahill v. Liberty Mutual 7 Ins. Co., 80 F.3d 336, 337–38 (9th Cir. 1996). To avoid a Rule 12(b)(6) dismissal, a 8 complaint need not contain detailed factual allegations, rather, it must plead “enough facts 9 to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 10 544, 570 (2007). A claim has “facial plausibility when the plaintiff pleads factual content 11 that allows the court to draw the reasonable inference that the defendant is liable for the 12 misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 13 U.S. at 556). “Where a complaint pleads facts that are ‘merely consistent with’ a 14 defendant’s liability, it stops short of the line between possibility and plausibility of 15 ‘entitlement to relief.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 557). 16 “[A] plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment] to relief’ 17 requires more than labels and conclusions, and a formulaic recitation of the elements of a 18 cause of action will not do.” Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 19 U.S. 265, 286 (1986) (alteration in original)). A court need not accept “legal conclusions” 20 as true. Iqbal, 556 U.S. at 678.

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Escamilla Avina v. Patenaude & Felix, APC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/escamilla-avina-v-patenaude-felix-apc-casd-2021.