11.  Plaintiff brings this claim on behalf of the following class, 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 New Jersey;  b. to whom Defendant AR sent an initial letter;   c. attempting to collect a consumer debt;  d. that states the recipient must notify the Defendant in writing within 30 days to  dispute the validity of the debt;  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 (21) days after the filing of this action.   13.  The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf it attempts to collect and/or has  purchased debts.   14.  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.    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.   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 the above allegations as if set forth here.   22.  The alleged debt arose from a financial obligation that was primarily for personal,  family, or household purposes, specifically medical services.   23.  RMA is a "creditor" as defined by 15 U.S.C.§ 1692a (4).   24.  Upon information and belief, RMA contracted with the Defendant AR to collect the  alleged debt.   25.  AR collects and attempts to collect debts incurred or alleged to have been incurred  for personal, family or household purposes on behalf of itself or other creditors using the United  States Postal Services, telephone and internet.  Violation – October 21, 2020 Collection Letter   26.  On or about October 21, 2020, Defendant sent Plaintiff an initial collection letter. A  copy of this letter is attached as Exhibit A.   27.  The letter states:   Unless you notify this office in writing within 30 days after  receiving this notice that you dispute the validity of this debt, or  any portion thereof, this office will assume this debt is valid.   28.  However, 15 U.S.C. § 1692g requires that an initial collection letter must include a  written notice containing - ...  (3) a statement that unless the consumer, within thirty days after receipt of the notice,  disputes the validity of the debt, or any portion thereof, the debt will be assumed to  be valid by the debt collector    29.  Defendant improperly stated that the dispute must be in writing which is untrue.   31.  These actions by Defendant deceive the consumer since he cannot properly evaluate  the actions required to dispute the debt.   32.  Had Plaintiff known a phone call would have sufficed to dispute the debt she may  have done so.   33.  Defendant’s letter created an appreciable risk to Plaintiff of being unable to properly  assert her rights.   34.  Plaintiff would have pursued a different course of action were it not for Defendants’  statutory violations.   35.  Because of this, Plaintiff expended time, money, and effort in determining the proper  course of action.   36.  These violations by Defendants were knowing, willful, negligent and/or intentional,  and Defendants did not maintain procedures reasonably adapted to avoid any such violations.   37.  Defendants’ collection efforts with respect to this alleged debt from Plaintiff caused  Plaintiff to suffer concrete and particularized harm, inter alia, because the FDCPA provides Plaintiff  with the legally protected right to be not to be misled or treated unfairly with respect to any action  for the collection of any consumer debt.   38.  Defendants’ deceptive, misleading, and unfair representations with respect to its  collection efforts were material misrepresentations that affected and frustrated Plaintiff's ability to  intelligently respond to Defendants’ collection efforts because Plaintiff could not adequately  respond to Defendants’ demand for payment of this debt.   40.  Plaintiff was confused and misled to her detriment by the statements in the dunning  letter, and relied on the contents of the letter to her detriment.   41.  As a result of Defendants’ deceptive, misleading and false debt collection practices,  Plaintiff has been damaged.  42.  Plaintiff repeats the above allegations as if set forth here.   43.  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.   44.  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.   45.  Defendant violated 15 U.S.C. §1692e:  a. By requiring a dispute of the debt be made in writing or the debt would be  assumed valid, in violation of § 1692e (5);  b. By falsely requiring a dispute of the debt be made in writing in violation of §§  §1692e and 1692e (10).   46.  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.  48.  In the alternative, 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.   49.  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.   50.  Defendant violated this section by requiring that a dispute of the debt be made in  writing.   51.  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.  52.  Plaintiff repeats the above allegations as if set forth here.   53.  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. § 1692g.   55.  Defendant violated this section by adding the false requirement that the dispute be in  writing.   56.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692g 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.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.  