74.  Plaintiff incorporates the above paragraphs as though set forth in full.   75.  Plaintiff is a “consumer” as defined by CCRAA section 1785.3(b).   76.  Kaiser is a “person” as defined by CCRAA section 1785.3(j).   77.  As alleged above, Kaiser is a provider of Medi-Cal covered services.   78.  As alleged above, Kaiser knew that Plaintiff was covered by Medi-Cal when it  provided the Medi-Cal covered services.   79.  Kaiser violated CCRAA section 1785.25(a) when it, directly and/or through its  agent USCB, furnished information about Medi-Cal covered charges to consumer credit  reporting agencies concerning Plaintiff and members of the Joint Furnishing Class, information  that it knew or should have known was inaccurate.   80.  Kaiser violated CCRAA section 1785.25(a) when it, directly and/or through its  agent USCB, furnished “information regarding the rendering of the Medi-Cal covered services  to a consumer credit reporting agency” with respect to Plaintiff and members of the Joint  Furnishing Class, a violation of CAL. WELF. & INST. CODE § 14019.4(f).   81.  Kaiser violated CCRAA section 1785.25(a) when it, failed “to provide corrections  of, or instructions to delete, as appropriate, information regarding Medi-Cal covered services  previously furnished . . . to a consumer [credit] reporting agency” with respect to Plaintiff and  members of the Joint Furnishing Class, a separate violation of CAL. WELF. & INST. CODE  § 14019.4(f).   82.  As alleged above, Kaiser’s conduct harmed Plaintiff and members of the Joint  Furnishing Class.   85.  Plaintiff incorporates the above paragraphs as though set forth in full.   86.  Plaintiff is a “consumer” as defined by FCRA section 1681a(c).   87.  Kaiser is a “person” as defined by FCRA section 1681a(b).   88.  FCRA section 1681s-2(b)(1)(A) requires the recipient of “a dispute of with regard  to the completeness or accuracy of any information provided by a person to a consumer reporting  agency” to “conduct an investigation with respect to the disputed information.”   89.  FCRA section 1681s-2(b)(1)(E) states that “if an item of information disputed by  a consumer is found to be inaccurate or incomplete or cannot be verified after” any  reinvestigation of the dispute information, the person must modify, delete, or permantly block  the reporting of that item of information.   90.  As alleged above, Plaintiff disputed one or more items of information concerning  Medi-Cal covered services to one or more consumer credit reporting agencies.   91.  As alleged above, on or more of the consumer credit reporting agencies to which  Plaintiff disputed the items of information concerning the Medi-Cal covered services contacted  USCB regarding Plaintiff’s dispute.   92.  As alleged above, USCB contacted Kaiser in the course of its investigation of  Plaintiff’s dispute.   93.  As alleged above, Kaiser verified the charges concerning the Medi-Cal covered  services to USCB.   Grossly Negligent Billing Practices  On behalf of Plaintiff and the Negligent Billing Practices Class  and against Defendant Kaiser Foundation Health Plan, Inc.  112.  Plaintiff incorporates the above paragraphs as though set forth in full.  113.  Kaiser’s breach of its duty to exercise ordinary or skill in the management of its  billing practices and procedures with respect to Plaintiff and members of the Negligent Billing  Practices Class demonstrates either a want of even scant care or an extreme departure from the  ordinary standard of conduct.  114.  As a direct and proximate result of Kaiser’s conduct, Plaintiff and the members of  the Negligent Billing Practices Class suffered the harm alleged above.  115.  As a result of its gross negligence, Kaiser is liable to Plaintiff and the members of  the Negligent Billing Practices Class for the relief sought herein.  Violation of the California Unfair Competition Law  CAL. BUS. & PROF. CODE §§ 17200-17210  On behalf of Plaintiff and the Injunctive Relief Class  and against Defendant Kaiser Foundation Health Plan, Inc.   Violation of the California Consumer Credit Reporting Agencies Act  CAL. CIV. CODE § 1785.25(a)  On behalf of Plaintiff and the Joint Furnishing Class   and against Defendant Kaiser Foundation Health Plan, Inc.   Violation of the Fair Credit Reporting Act  15 U.S.C. § 1681s-2(b)  On behalf of Plaintiff and the Verification Class  and against Defendant Kaiser Foundation Health Plan, Inc.   Violation of the Fair Debt Collection Practices Act  15 U.S.C. §§ 1692-1692p  On behalf of Plaintiff and the Unlawful Collection Class  and against Defendant USCB, Inc.  136.  Plaintiff incorporates the above paragraphs as though set forth in full.  137.  Plaintiff is a “consumer” as defined by FDCPA section 1692a(3).  138.  USCB is a “debt collector” as defined by FDCPA section 1692a(6).  139.  As alleged above, USCB’s conduct with respect to Plaintiff and the members of  the Unlawful Collection Class violated, without limitation, the following sections of the FDCPA:  A.  FDCPA section 1692e(8), which prohibits the communication to any  person of credit information which a debt collector knows or should know is false; and  B.  FDCPA section 1692f(1), which prohibits the collection of any amount not  permitted by law.  140.  For its violations of the FDCPA, USCB is liable to Plaintiff and members of the  Unlawful Collection Class for the relief sought herein. 