18. Sometime before September 27, 2010, Plaintiff is alleged to have incurred  certain financial obligations.  52. Plaintiff bring this action on behalf of one class, enumerated here as “Class  One.”  53. Class One consists of (a) all natural persons with addresses inside California,  (b) who were sent a an initial written communication, as anticipated by the  FDCPA under 15 U.S.C. § 1692g(a) and was therefore incorporated by  California’s Rosenthal Act, which was similar or identical to the September  27, 2010 correspondence mailed to Plaintiff and attached hereto as Exhibit A, (c) on or after a date one year prior to the filing of this action, and (d) on or  before a date 20 days after the filing of this action.  54. There are more than 1000 members of the class, and the class members are so  numerous that joinder is impracticable.  59. Plaintiff repeats, re-alleges, and incorporates by reference, all other  paragraphs.  60. The foregoing acts and omissions constitute numerous and multiple violations  of the Rosenthal Act, including but not limited to each and every one of the  above-cited provisions of the Rosenthal Act, Cal. Civ. Code §§ 1788-1788.32  61. As a result of each and every violation of the Rosenthal Act, Plaintiff is  entitled to any actual damages pursuant to Cal. Civ. Code § 1788.30(a);  statutory damages for a knowing or willful violation in the amount up to  $1,000.00 pursuant to Cal. Civ. Code § 1788.30(b); and reasonable attorney’s  fees and costs pursuant to Cal. Civ. Code § 1788.30(c) from Defendant. COUNT I ROSENTHAL FAIR DEBT COLLECTION PRACTICES ACT (ROSENTHAL ACT) CAL. CIV. CODE §§ 1788-1788.32  Cite the U.S. Civil Statute under which you are filing  (Do not cite jurisdictional statutes unless diversity): Brief description of cause: VII.  REQUESTED IN