12.  This Action is properly maintained as a class action. The Class is initially defined  as:  • All New Jersey consumers who were sent letters and/or notices from ARS,  which included the alleged conduct and practices described herein.  The class definition may be subsequently modified or refined.    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.  Sometime before January 30, 2018, Plaintiff allegedly incurred financial  obligations to EMERGENCY PHYSICIAN ASSOCIATES OF SOUTH JERSEY, PC  33.  Collection letters and/or notices, such as those sent by Defendants, are to be  evaluated by the objective standard of the hypothetical “least sophisticated consumer.”   34.  Defendant’s collection letters and/or notices would cause the least sophisticated  consumer to be confused as to his or her rights.   35.  Defendant’s letters were designed to cause the least sophisticated consumer to be  confused as to his or her rights.   36.  The content of Defendant’s letter was designed to cause the least sophisticated  consumer to be confused about what Defendant meant by the statement that: “account(s) are  delinquent and may have been reported to the credit bureaus.”   37.  The content of Defendant’s letter was designed to cause a false sense of urgency  for the least sophisticated consumer to pay the obligation.    38.  Defendant’s letter would cause the least sophisticated consumer to be confused as to  whether every account listed in the January 30, 2018 letter would be eligible to be reported to credit  bureaus.   39.  The January 30, 2018 letter’s use of the word “may” does not remove from the  realm of possibility that the least sophisticated consumer would be deceived into thinking that  every account listed in the January 30, 2018 letter would be eligible to be reported to credit bureaus.   40.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by using any false,  deceptive or misleading representation or means in connection with its attempts to collect debts  from Plaintiff and others similarly situated.   42.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by creating a false sense of  urgency to pay the debts to avoid an impact to his credit file.   43.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by falsely representing to  Plaintiff that each and every account was eligible to be reported to one or more of the national  credit reporting agencies.   44.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by falsely representing to  Plaintiff that account number 69920525 was eligible to be reported to one or more of the national  credit reporting agencies.   45.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by falsely representing to  Plaintiff that account number 69979834 was eligible to be reported to one or more of the national  credit reporting agencies.   46.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by falsely representing to  Plaintiff that account number 71094327 was eligible to be reported to one or more of the national  credit reporting agencies.   47.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by falsely representing that  account number 69920525 was within the seven year period to be reported to one or more of the  national credit reporting agencies.   48.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by falsely representing that  account number 69979834 was within the seven year period to be reported to one or more of the  national credit reporting agencies.   50.  Defendants violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely  representing the character or legal status of the debt.   51.  Defendants violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely  representing to Plaintiff that account number 69920525 was eligible to be reported to one or  more of the national credit reporting agencies.   52.  Defendants violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely  representing to Plaintiff that account number 69979834 was eligible to be reported to one or  more of the national credit reporting agencies.   53.  Defendants violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely  representing to Plaintiff that account number 71094327 was eligible to be reported to one or  more of the national credit reporting agencies.   54.  Defendants violated 15 U.S.C. § 1692e(2)(A) of the FDCPA by falsely  representing to Plaintiff that the each and every account was eligible for being reported to one or  more of the national credit reporting agencies.   55.  Section 1692e(5) of the FDCPA prohibits a debt collector from threatening to take  any action that cannot legally be taken or that is not intended to be taken.   56.  Defendants violated 15 U.S.C. § 1692e(5) of the FDCPA by falsely threatening to  post information regarding account number 69920525 to one or more of the national credit  reporting agencies.   58.  Defendants violated 15 U.S.C. § 1692e(5) of the FDCPA by falsely threatening to  post information regarding account number 71094327 to one or more of the national credit  reporting agencies.   59.  Section 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.   60.  Defendants actions and conduct described herein violated 15 U.S.C. § 1692e(10).   61.  Congress enacted the FDCPA in part to eliminate abusive debt collection  practices by debt collectors.   62.  Plaintiff and others similarly situated have a right to free from abusive debt  collection practices by debt collectors.   63.  Plaintiff and others similarly situated have a right to receive proper notices  mandated by the FDCPA.   64.  Plaintiff and others similarly situated were sent letters which have the propensity  to affect their decision-making with regard to the debt.   65.  Plaintiff and others similarly situated have suffered harm as a direct result of the  abusive, deceptive and unfair collection practices described herein.   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS    RESOLUTION SERVICES; and JOHN DOES 1- 25,                                       Defendant(s).  Plaintiff, KEITH STACKHOUSE, on behalf of himself and all others similarly situated  (hereinafter “Plaintiff”) by and through his undersigned attorney, alleges against the above- named Defendant, HEALTHCARE REVENUE RECOVERY GROUP, LLC D/B/A ARS  ACCOUNT RESOLUTION SERVICES (“ARS”),  JOHN DOES 1-25 their employees, agents,  and successors (collectively "Defendants") the following: 