1. A Judgment against Defendant in favor of Plaintiff and the class members for statutory  damages, and costs and attorney’s fees; and   15. Plaintiff repeats and re-alleges the allegations contained in paragraphs 1-14 of this  Complaint.   16. Exhibit A sets forth the following: “As of the date of this letter, you owe $5,671.06”.   17. If on the date of Exhibit A American Express was not accruing interest, late charges,  and/or other charges on the aforementioned $5,671.06 set forth in Exhibit A, then  Defendant violated 15 USC § 1692g(a)(1), 15 USC § 1692e, and/or 15 USC § 1692e(10)  as a result of Exhibit A setting forth that Campo owed $5,671.06 “as of the date of this  letter”.  18. Plaintiff repeats and re-alleges the allegations contained in paragraphs 1-14 of this  Complaint.   19. Exhibit A sets forth the following: “As of the date of this letter, you owe $5,671.06”.   20. Upon information and belief, American Express continued to accrue interest, late charges,  and/or other charges on the $5,671.06 set forth in Exhibit A.   21. However, Exhibit A did not explain that interest, late charges, and other charges were  accruing, did not explain the basis for the accrual of any interest, late charges, and other  charges, and did not set forth what Campo would need to pay to resolve the debt at any  given moment in the future.   22. For the above reasons, as a result of the aforementioned omissions from Exhibit A,  Defendant violated 15 USC § 1692g(a)(1) and/or 15 USC § 1692e by sending Exhibit A to  Campo.  23. Plaintiff repeats and re-alleges the allegations contained in paragraphs 1-14 of this  Complaint.   24. Describing the “Balance” as being “as of the date of this letter” in and of itself fails to set  forth the amount of the debt as required by 15 USC § 1692g(a)(1) and amounts to a false,  deceptive or misleading means in connection with the collection of a debt in violation of 15  USC 1692e, 15 USC 1692e(2)(A), and/or 15 USC 1692e(10).  25. Plaintiff repeats and re-alleges the allegations contained in paragraphs 1-14 of this  Complaint.   26. Exhibit A amounted to a false, deceptive or misleading means in connection with the  collection of a debt in violation of 15 USC 1692e, 15 USC 1692e(2)(A), and 15 USC  1692e(10).  27. Plaintiff repeats and re-alleges the allegations contained in paragraphs 1-14 of this  Complaint.   28. By sending Exhibit A to Campo, Defendant violated 15 USC 1692g.  29. Plaintiff brings this action on behalf of a class pursuant to Fed. R. Civ. P. 23(a) and  (b)(3).   30. The class consist of (a) all natural persons (b) who received a letter from Defendant dated  between October 7, 2017 and the present, (c) to collect a past due consumer debt, (d) in a  form materially identical or substantially similar to Exhibit A.   31. The class members are so numerous that joinder is impracticable. On information and  belief, there are more than 50 members.   32. There are questions of law and fact common to the class members, which common  questions predominate over any questions that affect only individual class members.   33. The predominant common question is whether Defendant’s letters violate the FDCPA.   34. Plaintiff will fairly and adequately represent the interests of the class members. Plaintiff  has retained counsel experienced in consumer credit and debt collection abuse cases and  class actions.   35. A class action is the superior means of adjudicating this dispute.   36. Individual cases are not economically feasible.   WHEREFORE, Plaintiff requests the following relief:  