1. An order certifying that Count I may be maintained as a class action pursuant to Rule  23 of the Federal Rules of Civil Procedure and appointing Plaintiff and the  undersigned counsel to represent the class as previously set forth and defined above;   14. On October 17, 2017, Plaintiff allegedly incurred a financial obligation to Imagine  Consultants Essex in the amount of $47.30 related to medical services rendered to her  (the “Debt”).   15. The Debt arose out of a transaction in which the money, property, insurance or services  which were the subject of the transaction were primarily for personal, family or  household purposes, namely fees emanating from medical services rendered to the  Plaintiff.     16. Plaintiff’s personal medical Debt to Imaging Consultants Essex is a “debt” as defined by  15 U.S.C. §1692a(5).    17. Sometime after the incurrence of the Debt, but before the initiation of this action, Plaintiff  was alleged to have fallen behind on payments owed on the Debt.   18. On or before January 23, 2018, the Debt was referred by Imaging Consultants Essex to  OIS for the purpose of collections.    19. Defendant contends that the Debt is past-due and in default.    2. Adjudging that Online Information Services, Inc. violated 15 U.S.C. §§1692e and  1692g;   21. At the time the Debt was referred by Imaging Consultants Essex to OIS, the Debt was in  default.    22. At all times relevant hereto, Defendant acted in an attempt to collect the Debt.    23. On or about January 23, 2018, OIS mailed or caused to be mailed a letter (the “Letter”) to  Plaintiff. (Annexed and attached hereto as Exhibit A is a true copy of the letter dated  January 23, 2018 sent by Online to Plaintiff, except the undersigned counsel has in  accordance with Fed. R. Civ. P. 5.2 redacted the financial account numbers and  Plaintiff’s street address to protect her privacy).   24. OIS mailed the letter dated January 23, 2018 attached as Exhibit A as a part of their  efforts to collect the Debt.    25. Plaintiff received the letter attached as Exhibit A in the mail.    26. Plaintiff read the letter attached as Exhibit A upon receipt of the letter in the mail.    27. Exhibit A was sent in connection with the collection of the Debt.   28. Exhibit A seeks to collect the Debt.    29. Exhibit A states in relevant part, “ This is an attempt to collect and debt…”   3. An award of statutory damages for Plaintiff, and the class pursuant to 15 U.S.C.  §1692k;   30. Exhibit A conveyed information regarding the Debt including the Amount Owed of  $47.30, OIS Account and Pin numbers, and a demand for payment.   31. The Letter attached as Exhibit A is a “communication” as that term is defined by 15  U.S.C. §1692a(2).   32. The Letter attached as Exhibit A was the only letter or notice that Plaintiff received from  4. Attorneys’ fees, litigation expenses, and costs of suit pursuant to 15 U.S.C. §1692k;  and    44. Plaintiff incorporates by reference all the above paragraphs as though fully stated herein.   45. The Defendant’s above refenced conduct violates 15 U.S.C. §§1692, 1692e, 1692e(10),  1692g, 1692g(a)(1)-(5).    46. 15 U.S.C. §1692e provides:                   §1692e.   False or Misleading Representations  A debt collector may not use any false, deceptive, or misleading representation or means  in connection with the collection of any debt. Without limiting the general application of  the foregoing, the following conduct is a violation of this section:  (10) The use of any false representation or deceptive means to collect or attempt  to collect any debt or to obtain information concerning a consumer   48. Defendant violated §1692g because they sought to collect debts from the Plaintiff without  providing the initial disclosures mandated by 15 U.S.C. §1692g for those debts. OIS did  not provide any of the initial disclosures required by §1692g(a)(1)-(5) for any of the  accounts that made up the $734.55 amount listed in Exhibit B other than the account for  $47.30 referenced in Exhibit A.    50. Defendant violated 15 U.S.C. §1692e(10) their conduct of failure to provide validation  notices for accounts they are seeking to collect is misleading and deceptive.    51. The misleading and deceptive representation is material because it left Plaintiff uncertain  as to her rights regarding her right to know the amount of the debt she allegedly owed,  the name of her alleged creditor, her ability to dispute her alleged debt and her right to  request verification of the alleged debt.    52. Plaintiff has alleged a particularized injury because the Letter attached as Exhibit A was  were mailed and directed to her.   53. Plaintiff has alleged a concrete harm because the FDCPA creates a substantive right  under §1692e to be free from abusive debt communications and §1692g creates a  substantive right to receive certain information, and Defendant’s violations of the  FDCPA results in concrete harm to Plaintiff.   54. Be reason thereof, Defendant is liable to Plaintiff and the proposed class for judgment that the  Defendant’s conduct violated 15 U.S.C. §1692e and 15 U.S.C. §1692g and for statutory  damages, costs, and attorneys’ fees pursuant to 15 U.S.C. §1692k.   55. Plaintiff incorporates by reference all the above paragraphs as though fully stated herein.   56. This action is brought as a class action. Plaintiff brings this action on behalf of herself  and on behalf of all other persons similarly situated pursuant to Rule 23 of the Federal  Rules of Civil Procedure.    58. The class definition above may be subsequently modified or refined.    59. The proposed class specifically excludes the United States of America, the states of the  Third Circuit, counsel for the parties, the presiding United States District Court Judge, the  Judges of the United States Court of Appeals for the Third Circuit and the United States  Supreme Court.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  