In Rouse v. Law Offices of Rory Clark (S.D.Cal. 2006) 465 F.Supp.2d 1031, a suit that grew out of the defendants' attempts to recover on a debt owed by the plaintiff's father. The defendants obtained a default judgment and recorded an abstract of judgment against the plaintiff's property even though he had told them that he was not the debtor. He sued the defendants for violation of the Rosenthal Act and intentional infliction of emotional distress, and the defendants moved to strike these causes of action under the anti-SLAPP (strategic lawsuit against public participation) statute (Code Civ. Proc., 425.16). The court denied the motions, finding that the defendants had failed to make the threshold showing that the causes of action arose from activity protected by the anti-SLAPP law. (See generally Rusheen, supra, 37 Cal.4th at p. 1055.) In so deciding, the court noted among other things that the plaintiff was not a party to the debt collection litigation, and distinguished Rusheen on the ground that Rusheen involved a levy on the property of a judgment debtor, not a stranger to the action (Rouse, supra, at p. 1039, fn. 6).