13. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs above  herein with the same force and effect as if the same were set forth at length herein.   14. Some time prior to July 2, 2019, an obligation was allegedly incurred to SYNCHRONY  30. The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf they attempt to collect  and/or have purchased debts.   31. 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.   33. The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories.   34. 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  Plaintiff’s attorneys have any interests, which might cause them not to vigorously pursue  this action.   35. Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter  “FRCP”) Rule 23, individually and on behalf of the following consumer class: (a) all  individuals with addresses in the state of Virginia  (b) who were sent collection letters from  Defendant attempting to collect an alleged consumer debt on behalf of Midland Funding,  LLC (d) which offered the consumer three payment options, (e) and referred to such  payment options as a “discount program” (f) which was sent on or after a date one year  prior to the filing of this action and on or before a date 21 days after the filing of this action.   36. 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.   38. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs above  herein with the same force and effect as if the same were set forth at length herein.   39. 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.   40. Pursuant to 15 U.S.C. §1692e, a debt collector is prohibited from using false, deceptive, or  misleading representation in connection with the collection of a debt.   41. The Defendant violated said section by:  a.  Falsely representing the character, amount, and legal status of the alleged debt in  violation of 1692e(2);  b. Making false or deceptive representation in connection with the collection of a debt  in violation of 1692e(10).   42. By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's conduct  violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692e et seq.  