20. Sometime before July 10, 2010, Plaintiff is alleged to have incurred certain  financial obligations with Defendant.  21. These alleged obligations were money, property, or their equivalent, which is  due or owing, or alleged to be due or owing, from a natural person to another  person and are therefore a “debt” as that term is defined by California Civil  Code §1788.2(d), and a “consumer debt” as that term is defined by California  Civil Code §1788.2(f).  22. Sometime before July 10, 2010, Plaintiff and Defendant entered into a written  contract for the purposes of Plaintiff obtaining a line of credit with Defendant.  23. Sometime thereafter, Defendant sent, and Plaintiff received the terms and  conditions underlying the parties 2010 contract.   24. Sometime thereafter, but before July 10, 2010, Plaintiff allegedly fell behind  in the payments allegedly owed on the alleged debt.  Plaintiff currently takes  no position as to the validity of this alleged debt.  25. Defendant’s 2010 contract stated in part that Defendant may, (i) “contact you  in any manner we choose,” including, “personal visit[s],”; (ii) “contact you in  any manner we choose,” including, “contact[ing] you at your home and at  your place of employment,”; (iii) “contact you at anytime, including  weekends and holidays,”; (iv) “contact you with any frequency,”; (v) “leave  prerecorded and other messages on your answering machine/service and with  others,”; (vi) “identify ourselves, your relationships with us and our purpose  for contacting you even if others might hear or read it.”  43. Plaintiff repeats, re-alleges, and incorporates by reference, all other  paragraphs.  44. The foregoing acts and omissions constitute numerous and multiple violations  of the Rosenthal Act, including but not limited to each and every one of the  above-cited provisions of the Rosenthal Act, Cal. Civ. Code §§ 1788-1788.32  ROSENTHAL FAIR DEBT COLLECTION PRACTICES ACT (ROSENTHAL ACT) CAL. CIV. CODE §§ 1788-1788.32 