13. Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter  “FRCP”) Rule 23, individually and on behalf of the following consumer class (the  “Class”):  All consumers with an address in the state of New Jersey who received a collection  letter from the Defendant attempting to collect a debt or alleged debt owed to  Preventive Healthcare Assoc, that charged a collection charge amount not  authorized by the agreement creating the debt or permitted by law.    14. The Class period begins one year to the filing of this Action.   16. 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.   17. Some time prior to September 29, 2015, an obligation was allegedly incurred to Preventive  Healthcare Assoc. (“PHA”)   18. The PHA obligation arose out of a transaction in which money, property, insurance or  services, which are the subject of the transaction, are primarily for personal, family or  household purposes.   19. The alleged PHA obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   20. PHA is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   21. Defendant contends that the PHA debt is past due.   23. PHA hired the Defendant to collect on the alleged debt.   24. On or about September 29, 2015, the Defendant caused to be delivered to the Plaintiff a  collection letter in an attempt to collect the alleged AT&T debt. See Exhibit A.   25. The September 29, 2015 letter was sent or caused to be sent by persons employed by  Defendant as a “debt collector” as defined by 15 U.S.C. §1692a(6).   26. The September 29, 2015 letter is a “communication” as defined by 15 U.S.C. §1692a(2).   27. The front portion of the letter states:  28. Upon information and belief, there is no legal or contractual right for Defendant to charge  a collection costs.   29. By falsely representing a collection charge fee, to which the Defendant is not entitled to,  Defendant caused the Plaintiff a real risk of harm.  30. 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.   32. Pursuant to 15 U.S.C. § 1692e, a debt collector may not use any false, misleading and/or  deceptive means to collect or attempt to collect any debt or to obtain information  concerning a consumer.    33. The Defendants violated said section by falsely representing the amount of the debt in  violation of 15 U.S.C. §1692e(2)(A).   34. 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.  35. 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.   36. Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff violated  15 U.S.C. § 1692(f) of the FDCPA.   37. Pursuant to 15 U.S.C. § 1692(f)1, a debt collector may not use unfair or unconscionable  means to collect or attempt to collect any debt.   Without limiting the general application  of the foregoing, the following conduct is a violation of this section: (1) The collection of  any amount (including interest, fee, charge or expense incidental to the principal  obligation) unless such amount is expressly authorized by the agreement creating the debt  or permitted by law.   39. 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.  Creditor:  Preventive Healthcare Assoc    Principal Due:   $326.83  Account No.:  XXXX1803  Collection Charge Due:     $55.00  I.C. System Reference No.:XXXXX64-1-39 BALANCE DUE:  $382.39  $0.00 had been Paid Since Placement                 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.  