10.  On or about February 29, 2012 and May 11, 2012, DEFENDANT mailed or  caused to be mailed form collection letters to PLAINTIFFS, and each of them, in an attempt to  collect a consumer debt from PLAINTIFFS allegedly owed to another.  True and correct copies  of the form letters are attached hereto as Exhibit “1”.   11.  The form letters sent by DEFENDANT to PLAINTIFFS state, in pertinent part:   If you choose not to pay your account in full within 30 days from  the date of this letter, in accordance with Nevada Revised Statutes,  Red Rock Financial Services will prepare and record a Lien for  Delinquent Assessments on behalf of [the original creditor].   Additional fees estimated in the amount of $340.00 plus mailing  fees will be added to the above account to cover the cost of  preparing and/or recording the Lien for Delinquent Assessments.   Please note these are estimated costs.  A “30 day period” has been established for disputing the  validity of the debt.  Federal Law does not require Red Rock  Financial Services to wait the “30 day period” to prepare  and/or record the Lien for Delinquent Assessments.  The “30  day period”, according to Federal Law, begins when this letter  is received by you.  All disputes regarding the validity of the debt must be submitted in  written form to Red Rock Financial Services.  When the dispute is  received, Red Rock Financial Services will provide verification of  the debt and a copy of such verification will be mailed to you.   Collection efforts on the part of Red Rock Financial Services will  cease during the research process.  When the research is completed,  you will receive a written response.  In addition, Red Rock  Financial Services will provide you with the original creditor(s) and  address(es) if different from the current.  In the event that Red Rock  financial services does not receive in written form, a dispute of the  debt, Red Rock Financial Services will assume the debt is valid.   12.  In addition, these letters seek to collect unspecified “additional collection fees  and costs.”   14.  The second form letter states, in pertinent part:  As of the date of this letter, the “30 Day Period” is still in  effect.  In the case that Red Rock Financial Services does not  receive in written form a dispute of the debt, Red Rock  Financial Services will assume the debt is valid.  All disputes of  the validity of the debt must be submitted in written form to  Red Rock Financial Services.  When the dispute is received,  Red Rock Financial Services will provide verification of the  debt and a copy of each such verification will be mailed to you.   Upon receipt of a written dispute, collection efforts on the part  of Red Rock Financial Services will cease.  A written response  will be provided detailing the result of our findings regarding  said dispute.  Allowed by Nevada Revised Statutes, Red Rock Financial Services  may record a Notice of Default and Election to Sell no sooner then  [sic] the 31st day from the mailing of the Lien for Delinquent  Assessments.  As a courtesy to you, an Intent to Notice of Default  courtesy letter will be sent to you via first class mail at an  additional charge.   15.  This letter also seeks to collect unspecified “fines and collection fees and costs.”  16.  PLAINTIFFS repeat, re-allege, and incorporates by reference, paragraphs 1  through 15 inclusive, above.   19.  A class action is superior for the fair and efficient adjudication of the class  members’ claims as Congress specifically envisioned class actions as a principal means of  enforcing the FDCPA. See 15 U.S.C.§ 1692k.  The members of the class are generally  unsophisticated consumers, whose rights will not be vindicated in the absence of a class action.  Prosecution of separate actions by individual members of the classes would also create the risk  of inconsistent or varying adjudications resulting in the establishment of inconsistent or varying  standards and would not be in the best interest of judicial economy.    20.  If facts are discovered to be appropriate, PLAINTIFFS will seek to certify the  class under Rule 23(b)(3) of the Federal Rules of Civil Procedure.  21.  PLAINTIFFS repeat, re-allege, and incorporate by reference, paragraphs 1  through 20 inclusive, above.   23.  The form letters sent by DEFENDANT to PLAINTIFFS and the class members  are deceptive and misleading because they require that all disputes be submitted in writing in  violation of 15 U.S.C. section 1692g(a).  See Camacho v. Bridgeport Fin. Inc., 430 F.3d 1078,  1081-82 (9th Cir. 2005).   24.  As a result of the FDCPA violations by DEFENDANT, PLAINTIFFS are  entitled to statutory damages plus actual damages to be shown specifically at the time of trial.   25.  It has been necessary for PLAINTIFFS to obtain the services of an attorney to  pursue this claim and PLAINTIFFS are entitled to recover reasonable attorneys’ fees therefor.  26.  PLAINTIFFS repeat, re-allege, and incorporate by reference, paragraphs 1  through 25 inclusive, above.   28.  The form letters are deceptive and misleading, and violate 15 U.S.C. § 1692g(b)  in that PLAINTIFFS’ and the class members’ rights to dispute the debt are overshadowed in the  letter by DEFENDANT’S contradictory threat to record a lien on PLAINTIFFS’ and the class  members’ property and impose additional costs and fees if the debt is not paid in full within 30  days of the date of the letter.  See Swanson v. S. Or. Credit Serv., Inc., 869 F.2d 1222, 1225 (9th  Cir. 1989).    29.  As a result of the FDCPA violations by DEFENDANT, PLAINTIFFS are  entitled to statutory damages plus actual damages to be shown specifically at the time of trial.   30.  It has been necessary for PLAINTIFFS to obtain the services of an attorney to  pursue this claim and PLAINTIFFS are entitled to recover reasonable attorneys’ fees therefor.  31.  PLAINTIFFS repeat, re-allege, and incorporate by reference, paragraphs 1  through 30 inclusive, above.    33.  In the form letters, DEFENDANT demanded that PLAINTIFFS and the class  members pay additional unidentified “collection fees and costs,” “fees and costs,” and “fines  and collection fees” to DEFENDANT.   34.  The foregoing demands by DEFENDANT violated the FDCPA by attempting to  collect from PLAINTIFFS and the class members an amount incidental to the principal  obligation that is not expressly authorized or permitted.   35.  As a result of the FDCPA violations by DEFENDANT, PLAINTIFFS and the  class members are entitled to statutory damages plus actual damages to be shown specifically at  the time of trial.   36.  It has been necessary for PLAINTIFFS to obtain the services of an attorney to  pursue this claim and PLAINTIFFS are entitled to recover reasonable attorneys’ fees therefor.  BROUGHT BY PLAINTIFFS INDIVIDUALLY AND ON BEHALF OF  AND A CLASS OF SIMILARLY SITUATED PERSONS DEFINED HEREIN AS CLASS  ONE AND CLASS TWO  FOR VIOLATIONS OF THE FDCPA 15 U.S.C.§ 1692g(a)   BROUGHT BY PLAINTIFFS INDIVIDUALLY AND ON BEHALF OF  AND A CLASS OF SIMILARLY SITUATED PERSONS DEFINED HEREIN AS CLASS  ONE AND CLASS TWO  FOR VIOLATIONS OF THE FDCPA 15 U.S.C.§ 1692g(b)   BROUGHT BY PLAINTIFFS INDIVIDUALLY AND ON BEHALF OF  AND A CLASS OF SIMILARLY SITUATED PERSONS DEFINED HEREIN AS  CLASS ONE AND CLASS TWO  FOR VIOLATIONS OF THE FDCPA 15 U.S.C.§ 1692f  