13.  Logue, doing business as Logue Law, permits NDM to use its status as law firm  as a ‘front’ for NDM’s fraudulent debt settlement services.    14.  On information and belief, Logue permits NDM to use the Logue Law name and  letterhead in exchange for a monthly fee of $5,000 to solicit unwitting consumers by telephone  and in writing for debt settlement services. NDM’s employees even answer consumer telephone  calls as “Logue Law.”   15.  Defendants create a false illusion that Logue Law is performing the services,  when all of the purported debt settlement services, if any, are rendered solely by non-lawyers at  50.  Gregorio repeats, re-alleges and incorporates by reference paragraphs 1-49,  inclusive, above, as if fully set forth herein. Gregorio seeks to represent the following classes:   51.  Gregorio brings this action on behalf of two (2) classes:  A. Injunctive Class (DCCPPA and RICO Claims Only)  All natural persons in the United States who, three (3) years prior to the commencement  of this action, were solicited by the Defendants for debt settlement services.  B. Monetary Class  All natural persons in the United States who, three (3) years prior to the commencement  of this action, paid Defendants to perform debt settlement services.   53.  There questions of law and fact common to the class members, which common  questions predominate over any questions that affect only individual class members. The  common questions are:   Whether the Defendants have participated in a scheme to defraud or obtain money  by false pretenses, representations, or promises in violation of 18 U.S.C. § 1341  and 18 U.S.C. § 1341;   Whether the Defendants scheme constitutes an “enterprise” under RICO;   Whether the Defendants have committed a “pattern of racketeering activity”  under RICO;   Whether due to their uniform acts, Defendants were unjustly enriched or received  payments and/or monies that under the principles of equity they cannot retain;    Whether Defendants breached their fiduciary duties to Gregorio and the class  members;   Whether such practices violate District of Columbia Code § 28-3904 et seq.; and   The amount of damages the Monetary Class has sustained as a result of the  Defendants’ wrongful conduct, and the proper measure of such damages.    54.  The claims of Gregorio are typical of the claims of class members because of the  similarity, uniformity and common purpose of Defendants’ unlawful conduct. All claims are  based on the same facts and the same legal theories.   56.  Gregorio repeats, re-alleges and incorporates by reference paragraphs 1-55,  inclusive, above, as if fully set forth herein.   57.  In violation of 18 U.S.C. § 1962(c), Defendants have conducted, or participated  directly or indirectly, in a pattern of racketeering activity through the use of wire and mail by  soliciting unwitting consumers via telephone and in writing for debt settlement services under a  false illusion that Logue Law is performing the services, when all of the purported debt settlement  services were to be rendered solely by non-lawyers at NDM.   58.  In violation of 18 U.S.C. § 1962(d), Defendants have conspired to violate 18 U.S.C.  § 1962(c) by conducting, or participating directly or indirectly, in a pattern of racketeering activity  through the use of wire and mail by defrauding unwitting consumers via telephone and in writing  for debt settlement services under a false illusion that Logue Law is performing the services, when  all of the purported debt settlement services were to be rendered solely by non-lawyers at NDM.   60.  Gregorio and the class members seek a judgment in their favor against the  Defendants for treble the amount of damages suffered by them in the form of payments made to  Defendants as a result of its predicate acts and violations of Section 1962(c) and (d) of RICO,  together with treble the amount of interest due on payments delayed or withheld through the  Defendants’ predicate acts and RICO violations.   61.  Gregorio repeats, re-alleges and incorporates by reference paragraphs 1-60,  inclusive, above, as if fully set forth herein.   62.  The EFTA, and Regulation E promulgated thereunder, prohibit the initiation of  electronic funds transfers without authorization.   63.  Defendants violated the EFTA and Regulation E by initiating or causing to be  initiated electronic funds transfers from Gregorio and the class members’ bank accounts without  authorization.   64.  Defendants’ unauthorized electronic fund transfers were for personal, family, or  household purposes in that the automatic debits were made for purportedly rendering consumer  debt settlement services.    66.  Gregorio repeats, re-alleges and incorporates by reference paragraphs 1-65,  inclusive, above, as if fully set forth herein.   67.  This claim arises under 18 U.S.C. § 1964 which authorizes district courts to enjoin  violations of 18 U.S.C. § 1962, and under 28 U.S.C. § 2201 which authorizes associated  declaratory relief.   68.  As set forth in Count I above, Defendants have violated 18 U.S.C. §§ 1962(c) and  (d), and will continue to do so in the future against other consumers without injunctive relief.   69.  Enjoining the Defendants from committing these RICO violations in the future  and/or declaring their invalidity is appropriate as Gregorio and the class have no adequate remedy  at law and, as set forth in paragraphs 13-49 above, will suffer irreparable harm through additional  bank drafts without authorization and/or rendering any debt settlement services in the absence of  the Court’s declaratory and injunctive relief.   70.  Gregorio and the class members seek injunctive relief preventing the Defendants  from soliciting, engaging in, or seeking payment for debt settlement services. Gregorio and the  class members further pray for an award of attorneys fees and for such other and further relief as  the Court deems just and proper.  DECLARATORY AND INJUNCTIVE RELIEF UNDER 18 U.S.C. § 1964(A)   Defendants’ Conspiracy   VIOLATIONS OF THE RACKETEER INFLUENCED AND CORRUPT  ORGANIZATIONS ACT  18 U.S.C. § 1962 ET SEQ. AND 18 U.S.C. § 1964 ET SEQ.   VIOLATIONS OF THE FEDERAL ELECTRONIC FUNDS TRANSFER ACT (“EFTA”)  15 U.S.C. § 1693 AND REGULATION E UNDER 12 C.F.R. § 205  