1. The amount of the debt;   1. where the letter:  a. states that there are multiple creditors;  b. without stating the amount owed to each individual  creditor;   11.  Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of all individuals:   a. with addresses in the State of New Jersey;  b. to whom Defendant RMP sent an initial letter;   c. attempting to collect a consumer debt;  d. in two sub-classes:   13.  The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf it attempts to collect and/or has  purchased debts.   14.  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.    15.  There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal issue is  whether the Defendant’s written communications to consumers, in the form attached as Exhibit A,  violate 15 U.S.C. §§ 1692e, 1692f, and 1692g.   16.  The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories. 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 his attorneys  have any interests, which might cause them not to vigorously pursue this action.   19.  Depending on the outcome of further investigation and discovery, Plaintiff may, at  the time of class certification motion, seek to certify a class(es) only as to particular issues pursuant  to Fed. R. Civ. P. 23(c)(4).  2. The name of the creditor to whom the debt is owed; ...   20.  Plaintiff repeats the above allegations as if set forth here.   21.  Some time prior to February 14, 2020, an obligation was allegedly incurred to two  separate non-parties: U of M Physicians, and M Health Clinic and Surgery.   22.  These alleged debts were incurred as financial obligations that were primarily for  personal, family or household purposes and are therefore each a “debt” as that term is defined by 15  U.S.C. § 1692a (5), specifically for personal medical services.   23.  U of M Physicians and M Health Clinic and Surgery are each a "creditor" as defined  by 15 U.S.C.§ 1692a (4).   24.  According to the letter received by Plaintiff, U of M Physicians and M Health Clinic  and Surgery placed the accounts with the Defendant to collect the alleged debt.   25.  Defendant RMP collects and attempts to collect debts incurred or alleged to have  been incurred for personal, family or household purposes on behalf of itself or other creditors using  the United States Postal Services, telephone and internet.  Violation - February 14, 2020 Collection Letter   26.  On or about February 14, 2020, Defendant RMP sent Plaintiff a collection letter. A  true and accurate copy of this letter is attached as Exhibit A.   28.  The letter further states “[y]our delinquent balances totaling $2,461.57 have been  placed with us for collections.” (emphasis added).   29.  The letter fails to identify the amount owed to each of the two creditors.   30.  The consumer is confused as to how much debt is owed on each individual debt and  cannot properly decide how to address them.   31.  For example, one of the debts may be significantly less than the other. If so, the  consumer would perhaps choose to pay down the smaller balance first. The letter however, fails to  properly inform the consumer of the amount of the debt, instead lumping multiple debts together to  coerce payment.   32.  The letter further offers monthly payment plans “interest free”.   33.  However, Defendant is not actually charging any further interest.   34.  The implied claim that interest is accruing is therefore deceptive and false.   35.  Implying that the balance may increase is merely a deceptive collection tactic.   36.  The consumer is therefore unable to evaluate how much is truly being alleged as the  correct balance, is being misled at to the total owed, and cannot properly evaluate the offers of  settlement.    38.  As a result of Defendant's deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  39.  Plaintiff repeats the above allegations as if set forth here.   40.  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.   41.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   42.  Defendant violated said section by:   a. implying interest is accruing on the debt although no interest is actually being  collected or intended to be collected in violation of §§ 1692e (5);  b. falsely representing the character, amount or legal status of the debt in violation  of §1692e (2);  c. Failing to state the balance owed to each creditor in violation of § 1692e (10).   43.  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.  44.  Plaintiff repeats the above allegations as if set forth here.   46.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   47.  Defendant violated this section by   a. implying interest is accruing on the debt although no interest is actually being  collected or intended to be collected;  b. unfairly representing the character, amount or legal status of the debt;  c. failing to state the balance owed to each creditor.   48.  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.  49.  Plaintiff repeats the above allegations as if set forth here.   50.  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. § 1692g.   51.  Pursuant to 15 U.S.C. §1692g:  Within five days after the initial communication with a consumer in  connection with the collection of any debt, a debt collector shall, unless the  following information is contained in the initial communication or the  consumer has paid the debt, send the consumer a written notice containing –   53.  In addition, the implied statement that that interest is accruing overshadows the §  1692g notice and time language and coerces the consumer not to exert his rights under the FDCPA.   54.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692g 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.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.  