10.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   11.  The Class consists of:   a. all individual consumers;  b. to whom Defendant sent a collection letter attempting to collect a consumer debt;  c. for which the debt had already become a judgement;  d. that failed to include any information regarding the accrual of interest, fees and/or  costs associated with a judgment;  e. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.   12.  A sub-class consists of:  a. all individual consumers;  b. to whom Defendant sent a collection letter attempting to collect a consumer debt;  c. for which the debt had already become a judgement;  d. that failed to include any identifying information such as an Index number  associated with the case to which the judgment relates;  e. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.  4   13.  The identities of all class members and sub-class members are readily ascertainable  from the records of Defendant and those companies and entities on whose behalf they attempt  to collect and/or have purchased debts.   14.  Excluded from the Plaintiff Class and sub-class are the Defendant and all officers,  members, partners, managers, directors and employees of the Defendant and their respective  immediate families, and legal counsel for all parties to this action, and all members of their  immediate families.    15.  There are questions of law and fact common to the Plaintiff Class and sub-class,  which common issues predominate over any issues involving only individual class members.  The principal issue is whether the Defendants' written communications to consumers, in the  forms attached as Exhibit A, violate 15 U.S.C. § l692e and § l692g.   16.  The Plaintiff’s claims are typical of the class members and sub-class members, as all  are based upon the same facts and legal theories. The Plaintiff will fairly and adequately protect  the interests of the Plaintiff Class and sub-class defined in this complaint. The Plaintiff has  retained counsel with experience in handling consumer lawsuits, complex legal issues, and class  actions, and neither the Plaintiff nor her attorneys have any interests, which might cause them  not to vigorously pursue this action.   17.  This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a  well-defined community interest in the litigation:  a. Numerosity: The Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff Class and sub-class defined above is so numerous that joinder  of all members would be impractical.  5  b. Common Questions Predominate: Common questions of law and fact exist as  to all members of the Plaintiff Class and sub-class and those questions’  predominance over any questions or issues involving only individual class  members. The principal issue is whether the Defendants' written communications  to consumers, in the forms attached as Exhibit A violate 15 U.S.C. § l692e and §  l692g.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class members  and sub-class members. The Plaintiff and all members of the Plaintiff Class sub- class have claims arising out of the Defendants' common uniform course of  conduct complained of herein.  d. Adequacy: The Plaintiff will fairly and adequately protect the interests of the  class members and sub-class members insofar as Plaintiff has no interests that  are adverse to the absent class members. The Plaintiff is committed to vigorously  litigating this matter. Plaintiff has also retained counsel experienced in handling  consumer lawsuits, complex legal issues, and class actions. Neither the Plaintiff  nor her counsel have any interests which might cause them not to vigorously  pursue the instant class action lawsuit.  e. Superiority: A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a single  forum efficiently and without unnecessary duplication of effort and expense that  individual actions would engender.  6   18.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class and sub-class predominate over any questions affecting an individual member, and a class  action is superior to other available methods for the fair and efficient adjudication of the  controversy.   19.  Depending on the outcome of further investigation and discovery, Plaintiff may, at  the time of class certification motion, seek to certify a class(es) only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).  20.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   21.  Some time prior to January 6, 2021, an obligation was allegedly incurred to a  creditor, American Express.     22.  Upon information and belief, American Express received a judgment related to the  underlying debt.    23.  Upon information and belief, American Express retained Defendant Zwicker &  Associates, a Law Firm, to act as their agent in collecting the subject debt from the Plaintiff.    24.  The subject debt arose out of a credit card debt. The subject debt was incurred by  Plaintiff solely for personal, household or family purposes.   25.  The Plaintiff is a “consumer” as defined by 15 U.S.C.§ 1692a (3).   26.  The subject obligation is consumer-related, and therefore a "debt" as defined by 15  U.S.C.§ 1692a (5).  7   27.  Defendant was contracted for the purpose of collecting the subject debt on behalf of  American Express. Therefore, Defendant is a “debt collector” as defined by 15 U.S.C.§ 1692a  (6).  Violations – January 6, 2021 Collection Letter   28.  On or about January 6, 2021, Defendant sent the Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed to American Express. (See Letter at Exhibit A.)   29.  Towards the top of the letter, it states (Exhibit A):  37.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   38.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   39.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   40.  Defendant violated §1692e:   a. As the letter falsely represents the true amount of the debt in violation of §1692e  (2); and  b. As the letter falsely represents the character and legal status of the debt in  violation of §1692e(2)(A); and  c. By making a false and misleading representation in violation of §1692e(10).   41.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  9  42.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   43.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692g.   44.  Pursuant to 15 U.S.C. §1692g(a), a debt collector must provide notice of a debt,  including the amount of the debt.   45.  Defendant violated §1692g(a):   a. As the letter falsely represents the true amount and identity of the debt in  violation of §1692g(a)(1)   46.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant  conduct violated Section 1692g et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692g  et seq.  