25.  Plaintiff brings this action on behalf of himself and others similarly situated.   Specifically, Plaintiff seeks to represent a class of individuals defined as:  All Persons within the United States whom Bursey, within one year before the  date of this Complaint, attempted to collect interest on an alleged consumer  debt – that MSW retained Bursey to collect – that Bursey did not have the  right to collect.   26.  Defendants, their employees and agents are excluded from The Class.  Plaintiff  does not know the number of members in The Class, but believes the Class members number in  the hundreds, if not more.  Thus, this matter should be certified as a Class Action to assist in the  expeditious litigation of the matter.   34.  Plaintiff hereby incorporates the preceding paragraphs as if set forth in full.   35.  Based upon the foregoing, Defendant’s conduct violated the FDCPA.   36.  Plaintiff alleges that to the extent that Defendants’ actions, counted above,  violated the FDCPA, those actions were done knowingly and willfully.   37.  As a direct and proximate result of Defendants’ violations of the FDCPA, 15  U.S.C. § 1692 et seq., Plaintiff and the members of the Class have suffered injury, and may  recover from Defendant one thousand dollars ($1,000.00) in statutory damages in addition to  actual damages and reasonable attorneys’ fees and costs pursuant to 15 U.S.C. § 1692k.   38.  The violations of the FDCPA, 15 U.S.C. § 1692 et seq., described herein present  a continuing threat to members of the Class and members of the general public in that Plaintiff  is informed and believes and thereon alleges that Defendants continue to engage in these  practices, and will not cease doing so unless and until forced to do so by this Court.    7.  Within one year prior to the filing of this action, Defendant contacted Plaintiff to  collect an alleged debt originally stemming from a credit account with Credit One Bank with  account number ending in 6437 (“alleged debt”).     FAIR DEBT COLLECTION PRACTICES ACT    (By Plaintiff and The Class Against All Defendants)  