Firm News


Marc Rosenberg prevailed in Campbell v. Puget Sound Collections, Inc., 2022 WL 73867 (W.D. Wash. Jan. 7, 2022). Marc represented a collection agency against claims under the federal Fair Debt Collection Practices Act, Washington’s Consumer Protection Act and for Outrage. The claims revolved around two letters sent by the collector to plaintiff relating to charges relating to medical debt for which plaintiff claimed she was exempt due to Medicare coverage. Under undisputed facts, the charity care letter was issued under plaintiff’s maiden name, rather than her current name, and plaintiff had not advised her medical provider, insurer, or the agency as to the change of name. The U.S. District Court held that the sending of the two letters would not support a claim of outrage, and that the FDCPA and CPA claims failed because the agency did not make any error “given the information reasonably available to it, rather the erroneous collection was a simple mistake due in part to Plaintiff's failure to update her insurer of her name change, her inaction after being billed, and the apparent subterfuge of her attorney.”

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