(Violations of the FDCPA)   21.  Plaintiff repeats, reiterates and incorporates the allegations contained in  paragraphs numbered “1” through “20” herein with the same force and effect as if the  same were set forth at length herein.   22.  Upon information and belief, Defendant, on behalf of itself or a third-party,  began efforts to collect an alleged consumer debt from the Plaintiff.    23.  Upon information and belief, and better known to the Defendant,  Defendant commenced its campaign of communications with Plaintiff by sending  Plaintiff two (2) mass-produced form letters in the mail both dated December 11, 2013.   24.  One letter was a collection letter (hereinafter referred to as “Defendant’s  Collection Letter”) which bore Defendant’s letterhead with company name identifying  Defendant as “Law Office” (attached hereto as Exhibit “A”).     25.  Defendant’s Collection Letter began: “The above creditor has turned over  to us for collection your account in the sum of $____. Beneath this was a heading in  large type, upper case letters centered on the page: “VALIDATION NOTICE.”   26.  Said “validation notice” consisted of: “The amount shown is the amount  owed to the Creditor.” Immediately after this sentence begins Defendant’s required 30- day dispute language regarding consumer rights.   27.   Thereafter, with no space to separate it from the preceding text,  Defendant stated: “At this time no attorney with this firm has personally reviewed the  particular circumstances of your account.”   28.  Thereafter, with no space to separate it from the preceding text,  Defendant provided required FDCPA disclosures in all uppercase letters. Thereafter  Defendant informed the consumer that if they did not dispute the alleged debt or require  further information offered in the 30-day disclosure language and “wish to pay this  claim,” that they should contact Defendant’s office.   29.  Defendant’s Collection Letter was signed:   BY:___[Script initials “JS”]___  [Defendant’s company name]  34.  Plaintiff repeats, reiterates and incorporates the allegations contained in  paragraphs numbered “1” through “33” herein with the same force and effect as if the  same were set forth at length herein.   35.   15 USC §1692e – preface prohibits a debt collector from using any false,  misleading or deceptive representations in connection with the collection of a debt.    36.  The Defendant violated 15 USC §1692e – preface by creating a mass- produced form letter for dissemination to consumers as exemplified by Defendant’s  Collection Letter (Plaintiff’s Exhibit “A”) which uses deception throughout. Defendant’s  letter states that “The above creditor has turned over to us for collection your account,”  with no indication of whether “us” means attorneys but implying that it does by the  inclusion of “Law Office” above the company name in the masthead. Equally deceptive  is Defendant including a heading above the body of its letter in large, bold, upper case  type centered on the page: “VALIDATION NOTICE,” after which Defendant states “The  amount shown is the amount owed to the Creditor,” and then immediately continues,  “Unless you notify us with thirty days,” etc. stating the required 30-day disclosure  language in the same paragraph as the so-called “Validation Notice.”  Defendant has  deliberately designed the aforementioned letter so that all of the text following the  heading, in fact the entire letter, can be easily misconstrued as “validation” of the  consumer’s debt, which is clearly not the case. Further down, Defendant deceptively  squeezes the statement, “At this time no attorney with this firm has personally reviewed  the particular circumstances of your account,” with no space to separate the paragraph  from the preceding or following text. In clear contradiction of this statement, Defendant’s  Collection Letter was signed by John J. Sheerin, an attorney with Defendant’s firm, who  deceptively did not identify himself as an attorney, but beneath his signature printed the  name of his firm and a direction to “refer to” a “J. Kennedy” and a telephone number.  Evidence that Attorney Sheerin signed said letter is provided by Defendant’s Legal  Letter (Plaintiff’s Exhibit “B”) where Attorney Sheerin includes his name beneath his  signature. A comparison of Attorney Sheerin’s signatures in Plaintiff’s Exhibits “A” and  “B” evidence that they are identical.   Defendant dates two letters on the same day, falsely informing the Plaintiff  that they are debt collectors and no attorney has personally reviewed particular  circumstances of his account and at the same time that they have been retained as  attorneys for the creditor and enclose an executed Consent to Change Attorneys which  they claim has been sent to “the Court” for filing. Defendant’s Collection Letter  deliberately and deceptively prints, “Refer to: J. Kennedy” directly beneath Mr. Sheerin’s  signature and firm name, with no indication of “J. Kennedy’s” title. In Defendant’s Legal  Letter, J. Kennedy is identified as “Collection Manager” and Mr. Sheerin is not identified  as an attorney. Both letters conclude by asking the consumer to contact Defendant to  make a settlement. Taken together, Defendant letters clearly illustrate Defendant’s  deceitful and reprehensible attempts to imply legal action is imminent as a means to  compel Plaintiff and the consumer to cooperate with Defendant’s debt collection  objectives.   37.  15 USC §1692 f –preface prohibits a debt collector from using any unfair  or unconscionable actions in connection with the collection of a debt.               38.  The Defendant violated 15 USC §1692 f – preface by unfairly and  unconscionably mass-producing and sending letters, exemplified by Defendant’s  Collection Letter sent to Plaintiff, designed to convince consumer recipients that they  are being contacted regarding a debt with all the implications associated with a pending  legal procedure. Defendant prints a letter on letterhead indicating “Law Office” above  the company name, states that “The above creditor has turned over to us for collection  your account” without stating who “us” entails in order to encourage the belief that “us”  means attorneys. Moreover, by centering the large upper case, bold typed heading,  “VALIDATION NOTICE,” above the body of its letter, Defendant unfairly attempts to give  the impression that what follows is a validation of the consumer’s debt when said  “validation” consists of the words: “The amount shown is the amount owed to the  Creditor.”  Further, Defendant deliberately squeezes the language that no attorney has  reviewed the particular circumstances of the consumer’s account between required  dispute notification language and above the all upper case disclosure language that  “THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT,” etc.  Further  Defendant unfairly includes a signature of two initials, difficult to decipher, with no  identity of the individual who sent the letter so as to encourage the consumer to assume  it is from an attorney. By Defendant’s use of stationery with a legal masthead  designated “Law Office,” it’s illusive signature and failure to identify the signatory or the  individual, “J. Kennedy” whom the consumer is directed to “refer to,” and it’s misleading  design and placement of information, Defendant intends to unfairly intimidate and  unsettle consumers and convince them that legal action against them is imminent,  thereby provoking the consumer into contacting Defendant in furtherance of  Defendant’s debt collection objectives.    39.  As a result of Defendant’s violations of the FDCPA, Plaintiff has been  damaged and is entitled to damages in accordance with the FDCPA.  8.  Plaintiff brings this action as a class action, pursuant to Federal Rules of  Civil Procedure (“FRCP”) Rule 23, on behalf of himself and all persons/consumers,  along with their successors-in-interest, who have received similar debt collection notices  and/or letters/communications from Defendant which, as alleged herein, are in violation  of the FDCPA, as of the date of Plaintiff’s Complaint (the “Class”).  Excluded from the  Class is Defendant herein, and any person, firm, trust, corporation, or other entity  related to or affiliated with the defendant, including, without limitation, persons who are  officers, directors, employees, associates or partners of Defendant is impracticable.  Upon information and belief, hundreds of persons have received debt collection notices  and/or letters/communications from Defendant, which violate various provisions of the 