12.  This Action is properly maintained as a class action. The Class is initially defined  as:   All New Jersey consumers who were sent letters and/or notices from  VISGILIO-MCGRATH, LLC concerning a judgment, which contained at  least one of the alleged violations of 15 U.S.C. § 1692 et seq. herein.  The class definition may be subsequently modified or refined.  The Class  period begins one year to the filing of this Action.    14.  Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).   15.  Sometime prior to July 14, 2016, Plaintiff allegedly incurred a financial obligation  to MOUNTAINSIDE HOSPITAL, A N.J. CORP. (“MOUNTAINSIDE HOSPITAL”).   16.  The MOUNTAINSIDE HOSPITAL 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.   17.  The MOUNTAINSIDE HOSPITAL obligation is a "debt" as defined by 15  U.S.C. § 1692a(5).   19.  On or before July 14, 2016, MOUNTAINSIDE HOSPITAL referred the  MOUNTAINSIDE HOSPITAL obligation to VISGILIO-MCGRATH, LLC for the purpose of  collections.   20.  At the time MOUNTAINSIDE HOSPITAL referred the MOUNTAINSIDE  HOSPITAL obligation to VISGILIO-MCGRATH, LLC, the obligation was past due.   21.  At the time MOUNTAINSIDE HOSPITAL referred the MOUNTAINSIDE  HOSPITAL obligation to VISGILIO-MCGRATH, LLC, the obligation was in default.   22.  Defendant caused to be delivered to Plaintiff a letter dated July 14, 2016, which  was addressed to Plaintiff.  Exhibit A.   23.  The July 14, 2016 letter was sent to Plaintiff in connection with the collection of  the MOUNTAINSIDE HOSPITAL obligation.    24.  The July 14, 2016 letter is a “communication” as defined by 15 U.S.C. §  1692a(2).   25.  Upon receipt, Plaintiff read the July 14, 2016 letter.   26.  The July 14, 2016 letter stated in part that:  With reference to the above entitled matter, please be advised that  there remains a judgment against you and in favor of my client,  Mountainside Hospital, A N.J. Corporation.  The total amount due  currently stands at $2,374.68.   27.  The July 14, 2016 letter also stated in part that:   Until this is paid, it may appear on your credit report and  adversely impact your credit. Therefore, if you wish to resolve  this matter, prompt payment should be remitted directly to my  office made payable to “Andrea Visgilio-McGrath, LLC, Trust  Account.  (emphasis added).   29.  Pursuant to 15 U.S.C. § 1681c(a) et seq., the period is generally limited to a 7  year period.   30.  A payment made on a judgment has no effect as to whether a judgment continues  to appear on a credit report or not.   31.  A judgment appearing on a credit report will be deleted within the reporting  period allowed pursuant to 15 U.S.C. § 1681c(a) et seq. whether or not a payment is made on the  judgment.   32.  Defendant knew or should have known that its actions violated the FDCPA.   33.  Defendant could have taken the steps necessary to bring its actions within  compliance with the FDCPA, but neglected to do so and failed to adequately review its actions to  ensure compliance with the law.  36.  Plaintiff, on behalf of herself and others similarly situated, repeats and realleges all  prior allegations as if set forth at length herein.   37.  Collection letters and/or notices, such as those sent by Defendants, are to be  evaluated by the objective standard of the hypothetical “least sophisticated consumer.”   38.  Defendant’s collection letters and/or notices would cause the least sophisticated to  be confused as to whether the judgment would remain on his or her credit report if the debt was  paid.   39.  Defendant’s collection letters and/or notices would cause the least sophisticated  consumer to believe that making a payment of the judgment would have an effect on the whether  the judgment continued to appear on credit reports.   40.  Defendant’s letters were designed to cause the least sophisticated consumer to  believe that making a payment of the judgment would have an effect on the whether the  judgment continued to appear on credit reports.   41.  The content of Defendant’s letter was designed to cause the least sophisticated  consumer to believe that making a payment of the judgment would have an effect on the whether  the judgment continued to appear on credit reports.   42.  Defendants violated 15 U.S.C. § 1692e of the FDCPA by using any false,  deceptive or misleading representation or means in connection with their attempts to collect  debts from Plaintiff and others similarly situated.   44.  15 U.S.C. § 1681 et seq. allows a consumer to attempt to remove any reporting  that appears on a credit report which is inaccurate.   45.  15 U.S.C. § 1681c(a) et seq. limits the reporting period that collection items may  remain on a credit report to a 7 year period.   46.  Defendants’ false, deceptive and misleading statement that “Until this is paid, it  may appear on your credit report and adversely impact your credit. Therefore, if you wish to  resolve this matter, prompt payment should be remitted directly to my office made payable to  “Andrea Visgilio-McGrath, LLC, Trust Account.” would cause the least sophisticated consumer  to believe that the alleged debt was being reported to one or more credit reporting agencies and  that only a payment would cause it to be removed from the consumer’s credit history.   47.  Section 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.   48.  Defendants violated 15 U.S.C. § 1692e(10) by falsely representing that “Until this  is paid, it may appear on your credit report and adversely impact your credit.”   49.  Defendants’ attempt to collect the alleged debt through misrepresentations  violated various provisions of the FDCPA including but not limited to:  15 U.S.C. §§ 1692e and  1692e(10).   50.  Congress enacted the FDCPA in part to eliminate abusive debt collection  practices by debt collectors.   51.  Plaintiff and others similarly situated have a right to free from abusive debt  collection practices by debt collectors.   53.  Plaintiff and others similarly situated were sent letters which have the propensity  to affect their decision-making with regard to the debt.   54.  Plaintiff and others similarly situated have suffered harm as a direct result of the  abusive, deceptive and unfair collection practices described herein.   55.  Plaintiff has suffered damages and other harm as a direct result of the Defendants’  actions, conduct, omissions and violations of the FDCPA described herein.  WHEREFORE, Plaintiff demands judgment against Defendants as follows:  (a)  Declaring that this action is properly maintainable as a Class Action and  certifying Plaintiff as Class representative and the attorneys, Joseph K. Jones, Esq., and Glen H.  Chulsky, Esq., as Class Counsel;  (b)  Awarding Plaintiff and the Class statutory damages;  (c)  Awarding Plaintiff and the Class actual damages;  (d)  Awarding pre-judgment interest;  (e)  Awarding post-judgment interest.  (f)  Awarding Plaintiff costs of this Action, including reasonable attorneys'  fees and expenses; and  (g)  Awarding Plaintiff and the Class such other and further relief as the Court  may deem just and proper.  Dated: December 31, 2016  s/ Joseph K. Jones   Joseph K. Jones, Esq.   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS   