OPINION
NALBANDIAN, Circuit Judge.
Orlans, PC, a law firm acting on behalf of Wells Fargo Home Mortgage Inc., sent a letter on law-firm letterhead to Freddie and Linda Garland. The letter said Wells Fargo had referred the Garlands' loan to Orlans for foreclosure. But the letter also said that "[w]hile the foreclosure process ha[d] begun...
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