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 New York;  b. to whom Defendant sent a collection letter attempting to collect a consumer debt;  c. that imposed an additional fee for credit card payments;   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 Class are the Defendants and all officers, 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 believe, and on that basis allege, that  the Plaintiff Class 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 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 December 18, 2018, an obligation was allegedly incurred to  “Cleveland Clinic Main Campus/Family Heath.” (“Clinic”)   22.  The obligation arose out of a transaction involving medical services allegedly  provided to Plaintiff by the Clinic and which was incurred primarily for personal, family or  household purposes.   23.  The alleged Clinic obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   24.  Clinic is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   25.  Clinic 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 I – December 18, 2018 Collection Letter   27.  On or about December 18, 2018, Defendant sent the Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed to the Clinic.  See December 18, 2018 Collection  Letter – Attached hereto as Exhibit A.   28.  The collection letter indicated that Defendant charges a $3.50 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 was not authorized by the agreement  creating the debt.    31.  The addition of this collection fee also runs afoul of New York State Law.  N.Y. Gen.  Bus. Law § 601(2) specifically prohibits this type of action insomuch as the law states that “No  principal creditor, as defined by this article, or his agent shall…Knowingly collect, attempt to  collect, or assert a right to any collection fee, attorney’s fee, court cost or expense unless such  changes are justly due and legally chargeable against the debtor.   32.  Defendant misled and deceived Plaintiff into the belief that she falsely owed an  additional $3.50 if she elected to pay by credit card, when this charge is a violation of the  35.  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.   36.  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(2)(A).   37.  Pursuant to 15 U.S.C. §1692e(2)(A), a debt collector may not mischaracterize the  character, amount or status of a debt in connection with the collection of any debt.   38.  Defendant violated said section by:   a. Falsely charging a processing fee which altered the amount of the debt violation  of §1692e(2)(A).   39.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e(2)(A) of the FDCPA, in the form of actual damages, statutory  damages, costs and attorneys’ fees.  40.  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.   41.  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.   42.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representations or means in connection with the collection of any debt.   43.  Defendant violated said section by:   b. Making a false and misleading representation in violation of §1692e(10).   44.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e(10) of the FDCPA, in the form of actual damages, statutory  damages, costs and attorneys’ fees.  45.  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.   46.  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.   47.  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.   48.  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).   49.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f(1) of the FDCPA, in the form of actual damages, statutory  damages, costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e(2)(A)   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692f (1).   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e(10)  