In Baylor v. Mitchell Rubenstein & Assocs., P.C., No. 13-cv-01995 (D.D.C. July 31, 2015), plaintiff creditor brought an action against an attorney debt collector under the District of Columbia’s Debt Collection Law. Defendant asserted privilege as to numerous communications between it and Sunrise Credit Services, which defendant asserted acted as a “forwarder” for creditor Arrowood, meaning that Arrowood contacted Sunrise so that Sunrise would find and obtain services of a local D.C. debt collector. The court noted that such “forwarding” companies have become popular to help creditors easily access a large network of collection agencies across the country. The court found the record did not reflect that Sunrise had undertaken direct collection actions against plaintiff, and that its role appeared to be limited to that of an intermediary agent between Arrowood and defendant for the sole purpose of finding counsel for Arrowood. Applying D.C. law, the court held that the use of an intermediary under these circumstances did not destroy the confidential relationship between Arrowood and defendant, and therefore those communications were privileged.