1. anyone employed by counsel for Defendants in this action; and   1. The prosecution of separate actions by the individual members of the  Class would create a risk of inconsistent or varying adjudication with  respect to individual Class members which would establish  incompatible standards of conduct for Defendants;    1. a natural person;   1. natural persons;  6   1. whether Defendants violated the FDCPA;   2. who received a letter from MLA;   2. any Judge to whom this case is assigned, as well as their immediate  family and staff.  Numerosity   2. whether Plaintiff and other class members are entitled to statutory  damages, costs, and attorney’s fees under the FDCPA;  Typicality  7   2. who received a letter from MLA;   2. the prosecution of separate actions by individual Class members would  create a risk of adjudications with respect to them which would, as a  practical matter, be dispositive of the interests of other Class members  not parties to the adjudications, or substantially impair or impede their  ability to protect their interests; and    3. which letter failed to state the amount of any  alleged debt or debts;   3. Defendants have acted or refused to act on grounds generally  applicable to the Class, thereby making appropriate final and  injunctive relief with respect to the members of the Class as a whole.  9  /s/   3. and which letter failed to state the amount of any alleged debt or debts.    35.  The plaintiff, Britney Rudler, brings this action on behalf of herself and also on  behalf of a class of all other persons similarly situated, pursuant to Fed. R. Civ. P. Rule 23.   36.  Defendants have continuously sent letters virtually identical to Exhibit A to  consumers since at least October of 2017.   37.   Upon information and belief, Defendants have been sending such letters for a  significantly longer period.    38.  Plaintiff seeks to represent the Class (hereafter, “the Class”) defined as follows:   39.  All members of the Class are also members of one or more of the subclasses.    4. and who received that letter within three years of  the filing of the instant Complaint.    4. The class members are generally unsophisticated individuals unaware  of the protections afforded them by the FDCPA, which rights will not  be vindicated in the absence of a class action.  40.  Excluded from the Class and subclasses are:   41.  The Class and subclasses potentially include hundreds of members and are  sufficiently numerous that joinder of all members is impractical.   42.  Although the exact number of Class members are unknown to Plaintiff, they are  readily ascendable from Defendants’ records.  Existence and Predominance of Common Questions   43.  Common questions of law and fact exist as to Plaintiff and all members of the  Class and predominate over questions affecting only individual Class members.   44.  These common questions include, inter alia:   45.  Plaintiff Rudler’s claims are typical of the claims of the Class because, among  other things, Plaintiff is:   46.  Thus, Plaintiff’s claims—based on the same acts and/or omissions as the claims  of all other Class members—are typical of the claims of the Class.   47.  In other words, all of the claims are based on the same factual and legal theories  and the Plaintiff, together with each Class member, has been subjected the violations of the  FDCPA by Defendants.  Adequacy   48.  Plaintiff will fairly and adequately represent the interests of the class members.   Her interests do not conflict with the interests of the members of the Class she seeks to represent.   49.  Plaintiff has retained counsel with experience in prosecuting individual-against- large-entity litigation and with class actions.  There is no reason why this Plaintiff and her  counsel will not vigorously pursue this matter.  Superiority   50.  The class action is superior to other available means for the fair and efficient  adjudication of the claims at issue herein.    51.  The damages suffered by each individual Class member may be limited. Damages  of such magnitude are small given the burden and expense of individual prosecution of the  complex and extensive litigation necessitated by Defendant’s conduct.  8   52.  Further, it would be virtually impossible for the members of the Class effectively  to individually redress the wrongs done to them. Even if the members of the Class themselves  could afford such individual litigation, the court system could not.   53.  Individualized litigation presents a potential for inconsistent or contradictory  judgments. Individualized litigation increases the delay and expense to all parties and the court  system presented by the complex legal and factual issues of the case.   54.  By contrast, the class action device presents far fewer management difficulties,  and provides the benefits of single adjudication, economy of scale, and comprehensive  supervision by a single court.   55.  In the alternative, the Class may be certified because:   56.  Plaintiff re-alleges the above paragraphs as if set forth fully in this count.   57.  Defendants MLA and Malevitis violated 15 U.S.C. § 1692g(a)(1) by failing to  disclose the amount of the debt in its initial communication with Plaintiff and the Class.   58.  Plaintiff and Class members suffered confusion due to the Defendants’ failure to  provide the amount of the alleged debt in its initial letter.   59.  As a result of the Defendants’ violations of the FDCPA, Plaintiff and the Class  are entitled to an award of statutory damages, costs, and reasonable attorney fees. 