10.  On or about June 3, 2014, Portfolio filed a Complaint (the “Collection  Complaint”) in the Superior Court of New Jersey, Law Division-Special Civil Part,  Camden County, against Garcia.   11.  In the Collection Complaint, Portfolio sought a judgment for amounts  allegedly owed by Garcia on an alleged Citibank, N.A. credit card account.   12.  Portfolio alleged in the Collection Complaint that Garcia had entered  into an agreement for a credit card with Citibank, N.A./Sears.   13.  Portfolio further alleged that it was the purchaser and then-current  owner of Garcia’s alleged Citibank credit card account, and that this alleged  account was assigned to it by Citibank, N.A. on March 26, 2013.   14.  Portfolio further alleged that Garcia had failed to make required  payments and was in default in the amount of $6,139.75 on the alleged Citibank  credit card account that Portfolio had acquired.   16.  Garcia, by and through his then-retained counsel, filed an Answer to  Portfolio’s Collection Complaint (the “Answer”), and therein denied all of  Portfolio’s allegations pertaining to himself.   17.  Garcia also asserted 22 affirmative defenses in his Answer and  demanded judgment dismissing the Collection Complaint and awarding him  attorney’s fees and costs of suit.   18.  At or shortly after the time Garcia filed his Answer, he also served  discovery requests on Portfolio and demanded, inter alia, a copy of the alleged  application for credit on the alleged Citibank credit card account.   19.  Portfolio provided copies of certain documents, but did not produce  the original credit agreement.   20.  Portfolio’s collection claim was scheduled for trial on January 13,  2015.  On that day, Garcia and his counsel appeared for trial.   21.  Neither Portfolio nor its counsel appeared in court on the day of trial,  and the court dismissed the collection action.   23.  Garcia paid the lawyer who represented him in defending against the  Portfolio collection action several thousand dollars for his attorneys’ fees and case  costs.   24.  In the year preceding Garcia’s filing of this Class Action Complaint,  Portfolio filed over 12,000 debt-collection lawsuits in the New Jersey Superior  Courts, Law Division and/or Special Civil Parts against New Jersey residents.   25.  A random sampling of almost 500 of the dockets for these Portfolio- filed lawsuits covering all 21 counties in New Jersey and all months from May  2014 to May 2015 in which a Portfolio lawsuit was filed in the particular county  shows that Portfolio was represented by only six individual attorneys in all of these  collection lawsuits:  the four Portfolio in-house counsel based in Norfolk, Virginia  who are listed on the Collection Complaint filed against Garcia—Carrie A. Brown,  Esq.; Thomas M. Murtha, Esq.; Mark R. Garvey, Esq.; and Sheena Daneshyar,  Esq; plus two outside counsel from a single law firm based in Hackensack, New  Jersey—Glenn Garbus, Esq. and Ronald Ferraro, Esq. of Foster, Garbus & Garbus  30.  This action is brought and may properly proceed as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure.   Plaintiff brings this action on behalf of himself and others similarly situated.   Plaintiff seeks certification of a Class and a Subclass initially defined as follows:  42.  Plaintiff repeats and incorporates the allegations set forth in  paragraphs 1-41 in their entirety as if they were fully set forth here.   43.  Plaintiff and Class and Subclass members are “consumers” as defined  by 15 U.S.C. § 1692a(3).   44.  The debts owed or alleged by Defendant to be owed by Plaintiff and  Class and Subclass members are consumer “debts” as defined by 15 U.S.C. §  1692a(5).   45.  Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).   47.  The debt-collection lawsuit complaints filed by Defendant against  Plaintiff and Class and Subclass members falsely implied that Defendant was able  to and intended to prove the claims asserted therein, when in fact Defendant was  not able to and did not intend to prove those claims, but instead intended either to  obtain a default judgment or to induce settlement by the consumer, or else to  dismiss the lawsuit, without ever proving its claims.   48.  By filing debt-collection lawsuit complaints against Plaintiff and  Class and Subclass members without any ability or intent to prove the claims  asserted therein, Defendant violated the following provisions of the FDCPA:  A.  15 U.S.C. § 1692e by using a false, deceptive, or misleading  representation or means in connection with the collection of  alleged debts;  B.  15 U.S.C. § 1692e(5) by threatening to take action that is not  intended to be taken;  C.  15 U.S.C. § 1692e(10) by using false representations or  deceptive means to collect or attempt to collect alleged debts;  D.  15 U.S.C. § 1692f by using unfair or unconscionable means in  connection with the collection of alleged debts.   50.  Plaintiff and the Subclass have been damaged by Defendant’s  violations of the FDCPA in the amounts of the losses of money they incurred to  defend against, respond to, or otherwise resolve the collection lawsuits filed  against them by Defendant.   51.  As a result of Defendant’s violations of the FDCPA, Plaintiff and the  Subclass also are entitled to actual damages under 15 U.S.C. § 1692k(a)(1).  WHEREFORE, Plaintiff, on behalf of himself and others similarly situated,  demands judgment against Defendant as follows:  A.  For certification of this matter as a class action, appointing  Plaintiff as representative of the Class and Subclass, and  appointing the attorneys of Williams Cuker Berezofsky, LLC as  class counsel;  B.  For maximum statutory damages for Plaintiff and the Class  under the FDCPA, 15 U.S.C. § 1692k(a)(2)(B);  C.  For actual damages for Plaintiff and the Subclass under the  FDCPA, 15 U.S.C. § 1692k(a)(1);  D.  For reasonable attorneys’ fees and costs of suit in connection  with this action under the FDCPA, 15 U.S.C. § 1692k(a)(3);  E.  For pre-judgment and post-judgment interest; and  F.  For such other and further relief as Plaintiff and Class and/or  Subclass members may be entitled to or as the Court deems  equitable and just.  7.  Portfolio is not in the business of extending credit or selling goods or  services to consumers.   9.  Portfolio regularly collects or attempts to collect debts allegedly owed  to others that were incurred primarily for personal, family, or household purposes.  