1.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   10.  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.  14.  The Class consists of:   a. all individuals with addresses in the State of New Jersey;  b.  to whom Defendant sent a collection letter attempting to collect a consumer debt;  c. that used threatening and harassing language threatening legal review;  d. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.   15.  The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf they attempt to collect and/or  have purchased debts.   16.  Excluded from the Plaintiff Class are the Defendants and all officer, 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 Defendants' written communications to consumers, in the forms attached as  Exhibit A, violate 15 U.S.C. §§ l692e 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 his attorneys have any interests, which might cause them not to vigorously pursue this action.   2.  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.   20.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.   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, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   23.  Some time prior to January 21, 20121, an obligation was allegedly incurred to  Citibank, N.A. by the Plaintiff.   24.  The Citibank, N.A. obligation arose out of transactions in which money, property,  insurance or services which are the subject of the transactions were primarily for personal,  family or household purposes.   25.  The alleged Citibank, N.A. obligation is a “debt” as defined by 15 U.S.C. §1692a(5).   27.  Defendant Halsted, a debt collector, was contracted by Defendant Cavalry, the  current owner of the debt and also a debt collector, to collect the alleged debt which originated  with Citibank, N.A.   28.  Defendants collect and attempt 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 I – January 21,2021, 2019 Collection Letter   29.  On or about January 21, 2021, Defendant Halsted sent Plaintiff a collection letter  (the “Letter”) regarding the alleged debt currently owed to Defendant Citibank, N.A. See  Exhibit A.   3.  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.   30.  The letter states: “This account meets our client’s guidelines for placement with a  law firm.  However, if we can resolve this account, it will not be placed with a law firm.  I am  not an attorney and I cannot provide you with legal advice.  As of today, no attorney has  reviewed the particular circumstances of your account to determine whether a lawsuit should be  filed against you.  However, if a lawsuit is filed, the law firm will ask the court to enter a  judgment against you for the full amount that is owed on this account.  If a judgment is entered,  the law firm will be authorized to take further action to satisfy the balance owed on the judgment.   We are committed to working with our customers to resolve their accounts.  Please let me know  if this account can be resolved before our client proceeds with law firm placement.”   32.  Moreover, the letter goes into a detailed description about the legal process,  attempting to intimidate the Plaintiff, predicting the actions of a hypothetical law firm and the  legal process when Defendant is not a law firm and has no place discussing or predicting the  legal possibilities in such detail.   33.  Moreover, Defendant portrays the legal system in an inaccurate fashion to intimidate  the Plaintiff, in its statement that “if a lawsuit is filed, the law firm will ask the court to enter a  judgment against you for the full amount that is owed on this account.”   34.  This statement implies that immediately upon the filing of a lawsuit, the law firm can  simply “ask” for a judgment which it seems by the next sentence of Defendant would be entered  simply allowing the law firm “to take further action to satisfy the balance owed on the  judgment.”   35.  The description of the legal system in such a simplistic, frightening manner can only  serve to harass and intimidate the Plaintiff.   36.  Defendant Halsted is not a law firm and cannot bring a legal action and to threaten  the Plaintiff with legal action is deceptive, misleading and harassing because Defendant Halsted  cannot bring any legal action.   37.  As a result of Defendant’s deceptive misleading and false debt collection practices,  Plaintiff has been damaged.  4.  Defendant violated said section   a.  by making a false and misleading representation in violation of §1692e(10);  b.  by falsely representing the character, amount of legal status of the debt in  violation of §1692e(2)(A);   c.  my making the threat to take any action that cannot legally be taken or that is  not intended to be taken in violation of §1692e(5).   5.  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.  6.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   7.  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.   9.  Defendant violated this section by falsely threatening and harassing Plaintiff with the  letter containing false threats.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692f et seq.  