FCCPA/FDCPA/TCPA: servicer's communications with represented parties was debt collection activity in violation of FCCPA and FDCPA where parties' attorney had entered appearance in foreclosure proceeding in which servicer sought deficiency; servicer was debt collector where servicer began servicing debt only after default; monthly mortgage loan statements and loss mitigation letters were debt collection activities; use of predictive dialer can constitute violation of TCPA; plaintiffs' claims not compulsory counterclaims which must have been filed in underlying foreclosure – France v. Ditech Financial, LLC , 2018 WL 1695405, No.
