12.  Plaintiff repeats and realleges the allegations contained in paragraphs numbered  “1” through “11” herein with the same force and effect as if the same were set forth at length  herein.   13.  Upon information and belief, Defendant, on behalf of a third-party, began efforts  to collect an alleged consumer debt from Plaintiff.   14.  Defendant was attempting to collect on Plaintiff’s purportedly overdue account  with TD Bank N.A. alleged to be in the amount of $3,234.88 (the “Debt”).   15.  In an effort to begin collecting on the Debt, Defendant sent Plaintiff a debt  collection letter, dated March 23, 2018.   16.  On or about May 21, 2018, Plaintiff called Defendant to inquire about and dispute  the alleged Debt.   17.  A representative of Defendant answered the phone and identified herself as Kristen  Walker.   18.  Plaintiff explained that he disagreed with the balance.     19.  Plaintiff thereafter stated that he wanted to dispute the Debt over the phone.   20.  However, instead of simply accepting the dispute, Defendant’s representative  stated that Plaintiff could not dispute the debt over the phone because “disputing with me doesn’t  mean anything” and that Plaintiff has to send a formal letter of why he wants to dispute this bill.      21.  Defendant’s representative stated that Plaintiff could not dispute the Debt because  Plaintiff’s reason for disputing the debt “is not a dispute.”   22.  Defendant failed/refused to accept and investigate Plaintiff’s oral dispute.     24.  Plaintiff repeats and realleges the allegations contained in paragraphs numbered  “1” through “27” herein with the same force and effect as if the same were set forth at length  herein.   25.  Defendant’s debt collection efforts attempted and/or directed towards Plaintiff  violated § 1692e of the FDCPA by using false, deceptive, and misleading representations in  connection with the collection of a debt.   26.  The FDCPA allows the consumer to orally dispute a debt.  See, Brady v. The Credit  Recovery Company, Inc., 160 F.3d 64 (1st Cir. 1998)(The FDCPA does not limit the time period  for disputing a debt. A consumer can always dispute a debt with a debt collector, regardless of the  passage of time); Register v. Reiner, Reiner & Bendett, P.C., 488 F.Supp.2d 143 (D.Conn. 2007);  Vega v. Credit Bureau Enters., No. CIVA02CV1550, 2005 WL 711657 (E.D.N.Y. Mar. 29, 2005);  Nasca v. GC Servs. Ltd. P'ship, No 01CIV10127, 2002 WL 31040647 (S.D.N.Y. Sept. 12, 2002);  In re Risk Mgmt. Alternatives, Inc., Fair Debt Collection Practices Act Litig., 208 F.R.D. 493  (S.D.N.Y. June 14, 2002); Castro v. ARS Nat'l Servs., Inc., No. 99 CIV. 4596, 2000 WL 264310  (S.D.N.Y. Mar. 8, 2000); Ong v. Am. Collections Enter., No. 98-CV-5117, 1999 WL 51816  (E.D.N.Y. Jan. 15, 1999).    27.  Defendant is required to accept Plaintiff’s oral dispute over the telephone.  Hooks  v. Forman, Holt, Eliades & Ravin, L.L.C., 717 F.3d 282 (2d Cir. 2013); Abramov v. I.C. Sys., Inc.,  54 F. Supp. 3d 270 (E.D.N.Y. 2014).   28.  The FDCPA does not require the consumer to provide any reason at all in order to  dispute a debt.  See, Castro v. ARS National Servs., Inc., 2000 WL 264310 (S.D.N.Y. Mar. 8,  2000); DeSantis v. Computer Credit, Inc., 269 f.3d 159 (2nd Cir. 2001).   30.  After Plaintiff disputed the Debt, Defendant continued to assume that Plaintiff’s  Debt was still valid.     31.  Defendant unilaterally denied Plaintiff’s oral dispute.       32.  Defendant violated § 1692e by not accepting Plaintiff’s dispute over the telephone.   33.  Defendant further violated § 1692e by requiring a reason for the dispute.          34.  Defendant and its employees, intentionally denied Plaintiff her dispute rights  afforded to her under the FDCPA.   35.  Defendant and its employees wrongfully failed to accept Plaintiff’s oral dispute.     36.  Defendant and its employees, wrongfully implied to Plaintiff that a dispute needs  to be deemed valid in order for it to be considered a dispute.   37.  Upon information and belief, Defendant and its employee, by intentionally denying  Plaintiff and any other debtor to dispute the debt orally and without a valid reason unfairly  intimidate and force debtors in to paying disputed debts.   38.  As an actual and proximate result of the acts and omissions of Defendant and its  employees, Plaintiff has suffered actual damages and injury, including but not limited to, fear,  stress, mental anguish, emotional stress, acute embarrassment and suffering for which she should  be compensated in an amount to be established by a jury at trial. 