    VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.   1. The amount of the debt;   10.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   11.  The Class consists of:   a. all individuals with addresses in the State of New Jersey;  b. to whom Defendant Portnoy sent an initial collection letter;   c. attempting to collect a consumer debt;  d. that failed to properly identify the name of the current creditor to whom the debt  was allegedly owed;   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.   12.  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.  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 Defendant’s written communications to consumers, in the form attached as Exhibit A,  violate 15 U.S.C. §§ 1692e and 1692g.   15.  The Plaintiff’s 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  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 his attorneys  have any interests, which might cause them not to vigorously pursue this action.   17.  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.   18.  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).  2. The name of the creditor to whom the debt is owed;   20.  On a date better known to Defendant, an obligation was allegedly incurred to creditor  Citibank, N.A.   21.  The alleged debt 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, specifically non-payment for credit card purchases.    22.  The alleged Citibank obligation is a "debt" as defined by 15 U.S.C.§ 1692a (5).   23.  Upon information and belief, Citibank transferred the debt to other parties.   24.  Upon information and belief, the current creditor contracted with Portnoy to collect  the alleged debt.   25.  Defendant collects and attempts to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of themselves or other creditors using  the United States Postal Services, telephone and internet.  Violation I – August 14, 2020 Letter   26.  On or about August 14, 2020 Defendant sent Plaintiff an initial collection letter  regarding the alleged debt owed. A true and accurate copy of this letter from Defendant is attached  as Exhibit A.   27.  This letter allegedly contains some of the required disclosures set forth in 15 U.S.C.  § 1692g (a).   28.  The letter states:  Our Client: CAVALRY SPV I, LLC  Original Creditor: Citibank, N.A.   30.  The term “our client” does not make it clear to the Plaintiff if this party is the current  creditor, or what exactly their role is in the collections process.    31.  It is deceptive not to clearly state who the current creditor is in a collection letter sent  to a consumer.   32.  The FDCPA requires that a letter must specifically and clearly state who is the  current creditor.   33.  Defendant failed to provide the consumer with a proper initial communication letter  by failing to clearly identify the current creditor of the debt.   34.  As a result of Defendant’s deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  35.  Plaintiff repeats the allegations contained in the above paragraphs as if set forth here.   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.   37.  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.   38.  Defendant violated §1692e by failing to properly identify the current creditor.    39.  By reason thereof, Defendant are 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.  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. § 1692f.   42.  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.   43.  Defendant violated this section by failing to identify the current creditor pursuant to  § 1692g.   44.  By reason thereof, Defendant are 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.  45.  Plaintiff repeats the allegations contained in the above paragraphs as if set forth here.   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. § 1692g.   47.  Pursuant to 15 USC §1692g:  Within five days after the initial communication with a consumer in  connection with the collection of any debt, a debt collector shall, unless the  following information is contained in the initial communication or the  consumer has paid the debt, send the consumer a written notice containing –   49.  By reason thereof, Defendant are 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. §1692f et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692g et seq.  