11.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of:   a. all individuals with addresses in the State of Ohio;  b. to whom Defendant sent a collection letter attempting to collect a consumer debt;  c. regarding collection of a debt;  d. that imposed an additional service fee for credit card payments;   e. 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.   13.  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.   14.  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.    15.  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.   16.  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.   17.  This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a  well-defined community interest in the litigation:  a. Numerosity: The Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff Class defined above is so numerous that joinder of all members  would be impractical.  b. Common Questions Predominate: Common questions of law and fact exist as  to all members of the Plaintiff Class and those questions predominance over any  questions or 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 § l692e and §1692f.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class members.  The Plaintiff and all members of the Plaintiff Class have claims arising out of the  Defendants' common uniform course of conduct complained of herein.  d. Adequacy: The Plaintiff will fairly and adequately protect the interests of the  class members insofar as Plaintiff has no interests that are adverse to the absent  class members. The Plaintiff is committed to vigorously litigating this matter.  Plaintiff has also retained counsel experienced in handling consumer lawsuits,  complex legal issues, and class actions. Neither the Plaintiff nor her counsel have  any interests which might cause them not to vigorously pursue the instant class  action lawsuit.  e. Superiority: A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a single  forum efficiently and without unnecessary duplication of effort and expense that  individual actions would engender.   18.  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.   19.  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).  20.  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.   21.  Some time prior to February 21, 2020, obligations were allegedly incurred to  University Hospitals Geauga Regional and Cleveland Clinic.   22.  The University Hospitals Geauga Regional and Cleveland Clinic obligations arose  out of transactions involving a involving a medical debt incurred by Plaintiff with University  Hospitals Geauga Regional and Cleveland Clinic in which money, property, insurance or  services, which are the subject of the transaction, were incurred for medical services.   23.  The alleged University Hospitals Geauga Regional and Cleveland Clinic obligation  is a "debt" as defined by 15 U.S.C.§ 1692a(5).   24.  University Hospitals Geauga Regional and Cleveland Clinic is a "creditor"(s) as  defined by 15 U.S.C.§ 1692a(4).   25.  University Hospitals Geauga Regional and Cleveland Clinic or a subsequent owner  of the University Hospitals Geauga Regional and Cleveland Clinic debt contracted with the  Defendant to collect the alleged debt.   26.  Defendant 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  – February 21, 2020 Collection Letter   27.  On or about February 21, 2020, Defendant sent the Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed to University Hospitals Geauga Regional and  Cleveland Clinic.  See Collection Letter – Attached hereto as Exhibit A.   28.  The collection letter indicated that Defendant charges a $3.50 service fee for payment  via credit card.   29.  Plaintiff did not agree to such a collection charge.   30.  The addition of this collection fee by Defendant which was not authorized by the  agreement creating the debt or permitted by law, was an attempt to collect an amount not owed  by Plaintiff.   31.  Defendant misled and deceived Plaintiff into the belief that she falsely owed an  additional $3.50 when this charge is a violation of the FDCPA.   32.  As a result of Defendant’s deceptive misleading and false debt collection practices,  Plaintiff has been damaged.  33.  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.   34.  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.   35.  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.   36.  Defendant violated said section by:   a. Making a false and misleading representation in violation of §1692e(10).   37.  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.  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. § 1692f.   40.  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.   41.  Defendant violated this section by   a.  unfairly advising Plaintiff that she owed Defendant more money than the  amount of her debt; and  b.  attempting to collect an amount not expressly authorized by the underlying  agreement creating the debt or permitted by law in violation of § 1692f(1).   42.  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.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692f et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  