1. The amount of the debt;   11.  Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of all individuals:   a. with addresses in the State of New Jersey;  b. to whom Defendant Paramount sent an initial letter;   c. attempting to collect a consumer debt;  d. providing multiple addresses;  e. without identifying which address is the correct one to send a written dispute to;  and  f. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (21) days after the filing of this action.   14.  Excluded from the Plaintiff Class are the Defendant and all officers, members,  partners, managers, directors and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate families.    15.  There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal issue is  whether the Defendant’s written communications to consumers, in the form attached as Exhibit A,  violate 15 U.S.C. §§ 1692e, 1692f, and 1692g.   16.  The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the Plaintiff  Class defined in this complaint. The Plaintiff has retained counsel with experience in handling  consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiff nor his attorneys  have any interests, which might cause them not to vigorously pursue this action.   18.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff Class  predominate over any questions affecting an individual member, and a class action is superior to  other available methods for the fair and efficient adjudication of the controversy.   20.  Plaintiff repeats the above allegations as if set forth here.   21.  Some time prior to June 2, 2020, an obligation was allegedly incurred to non-party  CF Medical, LLC.   22.  This alleged debt was incurred as a financial obligation that was primarily for  personal, family or household purposes and is therefore a “debt” as that term is defined by 15 U.S.C.  § 1692a (5), specifically for personal medical services.   23.  CF Medical, LLC is a "creditor" as defined by 15 U.S.C.§ 1692a (4).   24.  According to the letter received by Plaintiff, CF Medical, LLC placed the account  with the Defendant to collect the alleged debt.   25.  Defendant Paramount collects and attempts to collect debts incurred or alleged to  have been incurred for personal, family or household purposes on behalf of itself or other creditors  using the United States Postal Services, telephone and internet.  Violation - June 2, 2020 Collection Letter   26.  On or about June 2, 2020, Defendant Paramount sent Plaintiff a collection letter. A  true and accurate copy of this letter is attached as Exhibit A.   27.  The letter ostensibly provides the notices as required by 15 U.S.C. § 1692g regarding  disputing the debt.   29.  None of the three addresses are specifically identified as the correct address where  to send a written dispute.   3. A statement that unless the consumer, within thirty days after  receipt of the notice, disputes the validity of the debt, or any    30.  The consumer is therefore confused as to how to properly dispute the debt and  exercise his rights under § 1692g.   31.  Upon information and belief, disputes sent to one or more of these addresses will not  be honored by Defendant.   32.  This renders that address(es) as misleading the consumer into believing a proper  dispute can be sent there.   33.  As a result of Defendant's deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  34.  Plaintiff repeats the above allegations as if set forth here.   35.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   36.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   37.  Defendant violated said section:   a. By providing multiple addresses and not identifying which one should be used to  dispute the debt in violation of §1692e (10).   39.  Plaintiff repeats the above allegations as if set forth here.   4. portion thereof, the debt will be assumed to be valid by the debt- collector;   40.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692f.   41.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   42.  Defendant violated this section by providing multiple addresses and not identifying  which one should be used for disputing the debt.   43.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  44.  Plaintiff repeats the above allegations as if set forth here.   45.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692g.   46.  Pursuant to 15 U.S.C. §1692g:  Within five days after the initial communication with a consumer in  connection with the collection of any debt, a debt collector shall, unless the  following information is contained in the initial communication or the  consumer has paid the debt, send the consumer a written notice containing –   47.  Defendant violated this section by providing multiple addresses and not identifying  which one should be used for disputing the debt thereby failing to provide the proper notice required  by §1692g in an initial collection letter.   48.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692g et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  5. A statement that the consumer notifies the debt collector in  writing within thirty-day period that the debt, or any portion  thereof, is disputed, the debt collector will obtain verification of  the debt or a copy of a judgment against the consumer and a copy  of such verification or judgment will be mailed to the consumer  by the debt collector; and   6. A statement that, upon the consumer’s written request within the  thirty-day period, the debt collector will provide the consumer  with the name and address of the original creditor, if different  from the current creditor.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT                              15 U.S.C. §1692e et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.  