13.  Plaintiff brings this claim on behalf of the following case, pursuant to  Fed. R. Civ. P. 23(a) and 23(b)(3).   14.  The Class consists of:   a. all individuals with addresses in the State of Washington;  b.  to whom Defendant Convergent sent a collection letter attempting  to collect a consumer debt;  c. on behalf of Defendant LVNV;  d. containing settlement offers;   e. without disclosing that if a partial payment is made along with  signed, written acknowledgement, it will restart the statute of  limitations;  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 (2l) days  after the filing of this action.   15.  The identities of all class members are readily ascertainable from the  records of Defendants and those companies and entities on whose behalf they  attempt to collect and/or have purchased debts.   22.  Plaintiff repeats, reiterates and incorporates the allegations contained  in paragraphs numbered above herein with the same force and effect as if the  same were set forth at length herein.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15  U.S.C. §1692e et seq.  