10.  Defendant told Plaintiff that she still owed the debt.   11.  Defendant had no legal basis to demand payment from payment, because the  account had been fully satisfied as per the March 18, 2014 Satisfaction of Judgment filed in St.  Louis County.  12.  Upon information and belief, it is Defendant’s routine practice to violate the  FDCPA by attempting to debts allegedly owed to St. Anthony’s Medical Center without the legal  right to do so.   13.  This action is properly maintainable as a class action pursuant to Rule 23 of the  Federal Rules of Civil Procedure.  The class consists of the following persons:  3   14.  FDCPA class: all residents of the United States who within one year of January  12, 2015 that received a communication wherein Defendant was trying to collect a debt owed to  St. Anthony’s Medical Center when it had no legal right to do so.   15.  Members of the class are so numerous that joinder is impracticable.  Based on  Plaintiff’s and Plaintiff’s counsel’s research regarding consumer complaints, Defendant is a high  volume debt collector that attempts to collect many thousands of consumer debts throughout  Missouri, Illinois and the United States.     16.  Upon information and belief, Defendant has engaged in the improper collection  communications described above with hundreds of consumers.   17.  Plaintiff is a member of the class she seeks to represent.   18.  There are no unique defenses Defendant can assert against Plaintiff individually,  as distinguished from the class.   19.  Plaintiff will assure the adequate representation of all members of the class and  will have no conflict with class members in the maintenance of this action.  Plaintiff’s interests in  this action are typical of the class and are antagonistic to the interests of the Defendant.   Plaintiff has no interest or relationship with the Defendant that would prevent him from litigating  this matter fully.  Plaintiff is aware that settlement of a class action is subject to court approval  and she will vigorously pursue the class claims throughout the course of this action.   20.  A class action will provide a fair and efficient method to adjudicate this  controversy since the claims of the class members are virtually identical in that they raise the  same questions of law and involve the same methods of collection and telephone contact by the  Defendant.     21.  Most, if not all, the facts needed to determine damages are obtainable from the  Defendant’s records.   22.  The purposes of the FDCPA will be best effectuated by a class action.  4   23.  A class action is superior to other methods for the fair and efficient adjudication  of this controversy.     24.  Furthermore, as damages suffered by most members of the class are relatively  small in relation to the costs, expense, and burden of litigation, it would be difficult for members  of the class individually to redress the wrongs done to them.     25.  Many, if not all, class members are unaware that claims exist against the  Defendant.  There will be no unusual difficulty in the management of this action as a class  action.   26.  Four common questions of law and fact predominate over all individual questions  in this action.  The common questions are whether: (1) Defendant is a “debt collector” pursuant  to the FDCPA; (2) the liabilities that Defendant has sought to collect from class members  constitute “consumer debt” under the FDCPA; (3) whether Defendant attempting to collect St.  Anthony’s Medical Center debt when they have no legal right to do so.   27.  Because many class members are unaware of their claims and because their  claims are small in relation to the cost of an individual suit, a class action is the only proceeding  in which class members can, as a practical matter, recover.   28.  Plaintiff and Plaintiff’s counsel have the necessary financial resources to  adequately and vigorously litigate this class action.  Plaintiff’s counsel will fairly and adequately  represent and protect the interests of the Class.   29.  All Class members have been damaged in precisely the same fashion, by  precisely the same conduct.  The loss suffered by individual Class members is calculable and  ascertainable.  6.  On or about January 12, 2015, Defendant contacted Plaintiff by telephone calling  from (314) 925-9001 attempting to collect a debt once owed to St. Anthony’s Medical Center in  the amount of $731.45.   7.  During the call, Defendant told Plaintiff the debt was due and owing.   8.  The debt at issue was the basis of a lawsuit filed against Plaintiff in St. Louis  County with a case number of 13SL-AC03480.  A Satisfaction of Judgment was filed on March  18, 2014.   9.  Plaintiff informed Defendant that she had already paid the debt and that she was  no longer indebted to St. Anthony’s Medical Center.  