13.  Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   15.  The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf it attempts to collect and/or has  purchased debts.   16.  Excluded from the Plaintiff Class are the Defendants and all officers, members,  partners, managers, directors and employees of the Defendants and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate families.    17.  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 and 1692f.   18.  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 her attorneys  have any interests, which might cause them not to vigorously pursue this action.   21.  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).  22.  Plaintiff repeats the above allegations as if set forth here.   23.  Some time prior to December 2, 2020, Plaintiff allegedly incurred an obligation to  non-party Bucking Horse Emergency Physicians, LLC (“Bucking Horse”).   24.  The obligation arose out of transactions incurred primarily for personal, family, or  household purposes, specifically medical services.    25.  The alleged Bucking Horse obligation is a "debt" as defined by 15 U.S.C.§ 1692a  (5).   26.  Bucking Horse is a "creditor" as defined by 15 U.S.C.§ 1692a (4).   27.  According to Defendants’ letter, Pendrick is the current creditor of the Bucking  Horse debt.   28.  Pendrick 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.   29.  Pendrick is a debt buyer.   30.  Pendrick purchases or otherwise acquires consumer debt from creditor(s).   32.  Debt Recovery was collecting the Bucking Horse account on behalf of Pendrick.   33.  Pendrick hired Debt Recovery to collect this consumer debt.   34.  Debt Recovery collects and attempts to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United States  Postal Services, telephone and internet.  Violation – December 2, 2020 Collection Letter   35.  On or about December 2, 2020, Defendants sent Plaintiff a collection letter regarding  the alleged debt.  See Letter attached as Exhibit A.    36.  The letter states that “The law limits how long you can be sued on a debt. Because  of the age of your debt(s), the current creditor cannot sue you for it.”    37.  The letter further states, “Should you choose to make a payment for less than the  discounted offer it may be considered a partial payment and re-start the statute of limitations”.   38.  This statement is false, since under applicable law, the statute of limitations on the  alleged debt cannot be restarted by making a payment at all. See, Tex. Fin. Code Ann. § 392.307(d).   39.  Plaintiff was misled as to her rights.   40.  Plaintiff was misled into believing that making a partial payment or promise to pay  would restart the statute of limitation.   41.  Defendant’s actions were false, deceptive, and/or misleading.   42.  Plaintiff was concerned and confused by the Letter.    43.  Plaintiff was therefore unable to evaluate her options of how to handle this debt.   45.  Plaintiff was hesitant to make a partial payment due in part to Defendant’s false claim  that such a payment would restart the statute of limitation.   46.  In addition, Plaintiff suffered emotional harm due to Defendant’s improper acts.   47.  These violations by Defendants were knowing, willful, negligent and/or intentional,  and the Defendants did not maintain procedures reasonably adapted to avoid any such violations.   48.  Defendant’s collection efforts with respect to this alleged debt from Plaintiff caused  Plaintiff to suffer concrete and particularized harm, inter alia, because the FDCPA provides Plaintiff  with the legally protected right to be not to be misled or treated unfairly with respect to any action  for the collection of any consumer debt.   49.  Defendant’s deceptive, misleading and unfair representations with respect to its  collection efforts were material misrepresentations that affected and frustrated Plaintiff's ability to  intelligently respond to Defendant’s collection efforts because Plaintiff could not adequately  respond to Defendant’s demand for payment of this debt.   50.  Defendant’s actions created an appreciable risk to Plaintiff of being unable to  properly respond or handle Defendant’s debt collection.   51.  Plaintiff was confused and misled to her detriment by the statements in the dunning  letter, and relied on the contents of the letter to her detriment.   52.  Plaintiff would have pursued a different course of action were it not for Defendant’s  statutory violations.   53.  As a result of Defendant’s deceptive, misleading and false debt collection practices,  Plaintiff has been damaged.  54.  Plaintiff repeats the allegations above as if set forth here.   55.  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.   56.  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.   57.  Defendants violated said section as described above, by making false or misleading  representations in violation of §§ 1692e, 1692e (2)(A), 1692e (5) & 1692e (10).   58.  By reason thereof, Defendants 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.  59.  Plaintiff repeats the allegations above as if set forth here.   60.  Alternatively, 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. §  1692f.   61.  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.   62.  Defendants violated this section by unfairly misrepresenting that the time period for  filing suit may renew.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.  