10.  Plaintiff opened and used her Citi Preferred Card account for personal, family or  household purposes. Plaintiff did not open the account for business purposes.   11.  Plaintiff did not answer the phone call from P&B, which went to voicemail.   12.  P&B’s employee left a voicemail message for Plaintiff. The voicemail message  identified the caller as “Robert Powers,” stated that the caller was “a debt collector for P&B  Capital Group,” and was calling about Plaintiff’s “Citi Preferred Card.”   13.  Plaintiff received a second phone call from P&B on May 17, 2016, at 6:21 PM.   14.  The call on May 17, 2016 also went to Plaintiff’s voicemail.   15.  P&B’s employee left another voicemail message for Plaintiff. As with the May 2,  2016 phone call and voicemail, the May 17, 2016 voicemail message again identified the caller  as “Robert Powers,” stated that the caller was “a debt collector for P&B Capital Group,” and was  calling about Plaintiff’s “Citi Preferred Card.”   17.  Plaintiff received a third phone call from P&B on May 27, 2016, at 8:07 AM.   18.  The call on May 27, 2016 also went to Plaintiff’s voicemail.   19.  P&B’s employee left another voicemail message for Plaintiff. The message was  also from “Robert Powers” and followed the same script as the previous two calls.   20.  As of June 23, 2016, Plaintiff has not received any written communications from  34.  Plaintiff incorporates by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   35.  P&B first contacted Plaintiff by telephone on May 2, 2016.   36.  P&B contacted Plaintiff by telephone again on May 17, 2016 and May 27, 2016.   37.  P&B never provided a written debt validation notice to Plaintiff.   38.  P&B's conduct is misleading and confusing to the unsophisticated consumer, in  that the notice of Plaintiff’s debt validation rights was never provided. 15 U.S.C. § 1692g(a).   39.  The Defendant has therefore violated 15 U.S.C. §§ 1692e, 1692e(10), 1692g(a)  and 1692g(b).  41.  The Class is so numerous that joinder is impracticable.  Upon information and  belief, there are more than 50 members of the Class.   42.  There are questions of law and fact common to the members of the class, which  common questions predominate over any questions that affect only individual class members.   The predominant common question is whether the Defendant complied with 15 U.S.C. §§ 1692e,  1692e(10), 1692g, and 1692g(a)(2).   43.  Plaintiff’s claims are typical of the claims of the Class members.  All are based on  the same factual and legal theories.   44.  Plaintiff will fairly and adequately represent the interests of the Class members.  Plaintiff has retained counsel experienced in consumer credit and debt collection abuse cases.   45.  A class action is superior to other alternative methods of adjudicating this dispute.    Individual cases are not economically feasible.  8.  On or about May 2, 2016, at 5:20 PM, P&B called Plaintiff’s cellular telephone  regarding an alleged debt, allegedly owed to Citibank.   9.  The alleged debt that was the subject of P&B’s telephone call on May 2, 2016,  was a “Citi Preferred Card” credit card account.  