1.  the amount of the debt;   11.  Plaintiff brings this action as a class action, pursuant to Rule 23 of the Federal  Rules of Civil Procedure (hereinafter “FRCP”), on behalf of himself and all consumers and their  successors in interest (the “Class”), who have received debt collection letters and/or notices from  the Defendant which are in violation of the FDCPA, as described in this Complaint.   12.  This Action is properly maintained as a statewide class action. The Class consists  of:   All New Jersey consumers who were sent initial letters and/or notices from  ZUCKER, concerning a debt owed to Wells Fargo Bank, N.A., which did not  contain a validation notice pursuant to 15 U.S.C. §1692g et seq.   The Class period begins one year to the filing of this Action.   14.   Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. §1692a(3).    15.  ZUCKER collects and attempts to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and Internet.   16.   ZUCKER is a “debt collector” as defined by 15 U.S.C. §1692a(6).   17.  Sometime prior to March 12, 2013 Plaintiff allegedly incurred a financial  obligation to Wells Fargo, N.A. ("Wells Fargo").     19.  Prior to March 12, 2013, Plaintiff became delinquent on the Wells Fargo  obligation.   2.  the name of the creditor to who the debt is owed;   20.  On or before March 12,  2013, Wells Fargo referred Plaintiff past due obligation  to ZUCKER to begin foreclosure proceedings.   21.  On or about March 12, 2103, Wells Fargo mailed a letter to Plaintiff advising her  that, "The above loan file has been referred to our attorneys with instructions to begin  foreclosure proceedings... If you have any questions, please contact our attorney list below.  Zucker, Goldberg & Ackerman...." A copy of said letter is annexed hereto as Exhibit A except  that the undersigned attorney has, in accordance with Fed. R. Civ. P. 5.2 partially redacted the  financial account numbers in an effort to protect Plaintiff’s privacy.   22.  On or about April 3, 2013 Defendant ZUCKER, caused to be delivered to  Plaintiff a letter concerning the alleged Wells Fargo obligation. A copy of said letter is annexed  hereto as Exhibit B except that the undersigned attorney has, in accordance with Fed. R. Civ. P.   23.  The April 3, 2013 letter was sent or caused to be sent by persons employed by  ZUCKER as a “debt collector” as defined by 15 U.S.C. §1692a(6).    24.  The letter states, "ZUCKER, GOLDBERG & ACKERMAN, LLC -  3.  a statement that unless the consumer, within thirty days  after receipt of the notice, disputes the validity of the debt,  or any portion thereof, the debt will be assumed to be valid  by the debt collector,   35.   Section 1692e(10) makes it a violation of the FDCPA to the "...use of any false  representation or deceptive means to collect or attempt to collect any debt...".   36.  ZUCKER used false representations or deceptive means to collect or attempt to  collect the debt by failing to state the amount of the debt.    37.  Plaintiff repeats the allegations contained in paragraphs 1 through 36 as if the  same were set forth at length.   38.  Section 1692g(a) of the FDCPA requires the debt collector to give what is  commonly referred to as a thirty-day (30) notice within five (5) days of its initial communication  with the consumer and send the consumer a written notice containing:   39.  Defendants violated Section 1692g(a)(1) of the FDCPA as the April 3, 2013 letter  fails to state the amount of the debt.   4.  a statement that if the consumer notifies the debt collector  in writing within the thirty-day period that the debt, or any  portion thereof, is disputed, the debt collector will obtain  verification of the debt or a copy of a judgment against the  consumer and a copy of such verification or judgment will  be mailed to the consumer by the debt collector;   40.  Defendants violated Section 1692g(a)(3) of the FDCPA as the April 3, 2013 letter  fails to state "...unless the consumer, within thirty days after receipt of the notice, disputes the  validity of the debt, or any portion thereof, the debt will be assumed to be valid by the debt  collector."   41.  Defendants violated Section 1692g(a)(4) of the FDCPA as the April 3, 2013 letter  fails to state "...if the consumer notifies the debt collector in writing within the thirty-day period  that the debt, or any portion thereof, is disputed, the debt collector will obtain  verification of the  debt or a copy of a judgment against the consumer and a copy of such verification or judgment  will be mailed to the consumer by the debt collector."   5.2 partially redacted the financial account numbers in an effort to protect Plaintiff’s privacy.   FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692  VIOLATION OF 15 U.S.C. §1692g et seq.   FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692  VIOLATION OF 15 U.S.C. §1692e et seq.   