13. 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.   14. Some time prior to September 16, 2019, an obligation was allegedly incurred to CAPITAL  30. The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf they attempt to collect  and/or have purchased debts.   31. 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.   32. 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 forms attached  as Exhibit A, violate 15 U.S.C. § 1692e.   33. The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories.   36. 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.   37. 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).  38. 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.   39. 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. The Defendant violated said section by:  a.  Falsely representing the character, amount, and legal status of the alleged debt in  violation of 1692e(2);  b. Making false or deceptive representation in connection with the collection of a debt  in violation of 1692e(10).   42. 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.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §1692e et seq.  