11.  Plaintiffs bring 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 Texas;  b. to whom Defendant SG&B sent an initial collection letter attempting to collect a  consumer debt;  c. that deceptively implied that Defendant could bring legal action to collect a debt  in the State of Texas;  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.   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 Classes 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 Classes, which common  issues predominate over any issues involving only individual class members. The principal issue  is whether the Defendant's collection actions such as the referenced letters attached as Exhibit  A and B, violate 15 U.S.C. §§ l692e.   16.  The Plaintiffs' claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiffs will fairly and adequately protect the interests of the  Plaintiff Classes defined in this complaint. The Plaintiffs have retained counsel with experience  in handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiffs  nor their 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 Plaintiffs are informed and believe, and on that basis allege,  that the Plaintiff Classes defined above are 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 Classes and those questions predominance over  any questions or issues involving only individual class members. The principal  issue is whether the Defendant’s communications to consumers, in the forms  attached as Exhibit A and B violate 15 U.S.C. l692e.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class members.  The Plaintiffs and all members of the Plaintiff Classes have claims arising out of  the Defendants' common uniform course of conduct complained of herein.  d. Adequacy: The Plaintiffs will fairly and adequately protect the interests of the  class members insofar as Plaintiffs have no interests that are adverse to the absent  class members. The Plaintiffs are committed to vigorously litigating this matter.  Plaintiffs have also retained counsel experienced in handling consumer lawsuits,  complex legal issues, and class actions. Neither the Plaintiffs nor their 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  Classes 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, Plaintiffs 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.  On or before July 10, 2019 the Plaintiff incurred an obligation.   22.  The Schumacher Clinical Partners obligation arose out of transactions in which  money, property, insurance or services, which are the subject of the transaction, are primarily  for personal, family or household purposes.   23.  The Schumacher Clinical Partners obligation is a "debt" as defined by 15 U.S.C.  §1692a (5).   24.  Schumacher Clinical Partners is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   25.  Schumacher Clinical Partners contracted the Defendant SG&B to collect the alleged  debt.   26.  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 –July 10, 2019 Collection Letter   27.  On or around July 10, 2019 Defendant SG&B sent the Plaintiff an initial contact  notice (the “Letter”) regarding the alleged debt owed to Schumacher Clinical Partners. A true  and correct copy of the Letter is attached hereto as Exhibit A.   28.  The letter contains a Letterhead at the top of the page stating: “Law offices of Scheer,  Green, & Burke, Co. L.P.A.   29.  The letter further states: “The above-mentioned account has been referred to this  office for collection.  The amount stated above is the current balance due.”   30.  The letter ends stating: “Although we are a law firm, at this time, no attorney with  this firm has personally reviewed the particular circumstances of your account, evaluated your  case or made any recommendations concerning the validity of the creditor’s claims.”   31.  Finally, the letter is signed by the “Law Offices of Scheer, Green, & Burke, Co.  39.  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.   40.  Defendants 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.  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.   42.  Defendants violated § 1692e:   a. As the Letter it is open to more than one reasonable interpretation, at least one of  which is inaccurate.  b. By making a false and misleading representation in violation of §1692e(10).   43.  By reason thereof, Defendants are liable to Plaintiff for judgment that Defendants’  conduct violated Section 1692e et seq. of the FDCPA, and Plaintiff is entitled to an award of  actual damages, statutory damages, costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  