In Puttner v. Debt Consultants of America, 2009 WL 1604570 (S.D.Cal. 2009), Judge Hayes applied a liberal pleading standing to the FDCPA under FRCP 8.  The Plaintiff argued that “foundational facts need not be pled with particularity in order to state a claim under the FDCPA or the RFDCPA” and that “the Complaint alleges sufficient facts to support claims for violation of the FDCPA and the RFDCPA through allegations that Client Services is a “debt collector” that was attempting to collect a consumer “debt” within the meaning of the FDCPA and RFDCPA.”  Judge Hayes agreed, stating that,


The Complaint does not provide detail with respect to the content or frequency of the allegedly harassing communications made by Client Services. However, the Court finds that this lack of detail does not warrant dismissal of the FDCPA claim because the Complaint adequately alleges violations of several express provisions of the FDCPA, and in light of the liberal pleading standard articulated in Rule 8 of the Federal Rules of Civil Procedure. The Court concludes that the Complaint alleges sufficient facts to state a claim for violation of the FDCPA.