Excerpt: ...in the First Amended Complaint (“FAC”), Besse had a benign tumor in his right shoulder for many years. (FAC, ¶ 19.) Around the end of 2015, after several MRI tests, Besse was referred to the interventional radiology department at Stanford. (Id. at ¶ 19.) There, the doctor recommended that Besse try a “new procedure” using high intensity focused ultrasound (“HIFU”) instead of a more traditional treatment route such as surgery. (Ibid....

Excerpt: ...nt, ¶11.) On or about June 15, 2017, the Debt was sold to defendant Southwestern Investors Group, LLC (“SIG”) for collection purposes. (Complaint, ¶12.) Defendant SIG hired, contracted, or otherwise engaged Debt Recovery Solutions, LLC (“DRS”) to collect the Debt from plaintiff Edwards on defendant SIG's behalf. (Complaint, ¶14.) On or about June 20, 2017, DRS sent, or caused to be sent, a written communication to plaintiff Edwards at ...