                                     Defendant.  Plaintiff LORIANN MILLER (hereinafter, “Plaintiff”), a New Jersey resident, brings this  amended class action complaint by and through the undersigned attorneys, against Defendant  CAPITAL ACCOUNTS, LLC (hereinafter “Defendant”), individually and on behalf of a class of  all others similarly situated, pursuant to Rule 23 of the Federal Rules of Civil Procedure, based  upon information and belief of Plaintiff’s counsel, except for allegations specifically pertaining to  Plaintiff, which are based upon Plaintiff’s personal knowledge.  12. 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.   13. Some time prior to November 5, 2020, an obligation was allegedly incurred to KIDDIE  30. Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure (hereinafter  “FRCP”) Rule 23, individually and on behalf of the following consumer class.     31. The Class consists of: a) All consumers with addresses in the State of New Jersey b) who  were sent a collection letter or email from the Defendant c) attempting to collect a  consumer debt owed to KIDDIE ACADEMY CHILD CARE LRNG, d) that states  “Because of interest, late charges, and other charges that may vary from day to day, the  amount due on the day you pay may be greater.  Hence, if you pay the amount shown  above, an adjustment may be necessary after we receive your payment” (e) when no interest  or other charges were added or intended to be added (f) which letter was sent on or after a  date one year prior to the filing of this action and on or before a date 21 days after the filing  of this action.   33. 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.   34. 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 forms attached  as Exhibit A, violate 15 U.S.C. § 1692e and 1692g.   35. The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories.   36. 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  Plaintiff’s attorneys have any interests, which might cause them not to vigorously pursue  this action.   39. 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).  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, misleading  and/or deceptive means to collect or attempt to collect any debt or to obtain information  concerning a consumer.   43. The Defendant violated said section in its letter to the Plaintiff by:  a. Using a false, deceptive, and misleading representations or means in  connection with the collection of a debt;  b. Falsely representing the amount of the alleged debt in violation of  1692e(2)(A);  c. Making a false representation or using deceptive means to collect a debt in  violation of 1692e(10).   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. §  1692g.   47. Pursuant to 15 U.S.C. § 1692g, a debt collector must within five days of the initial  communication notify the consumer of his or her validation rights.   48. The Defendant violated said section in its letter to the Plaintiff by failing to accurately  state the amount of the debt in violation of 1692g(a)(1).   49. 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.  