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).   12.  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.   13.  Excluded from the Plaintiff Class are the Defendants and all officer,  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.    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 Defendants' written  communications to consumers, in the forms attached as Exhibit A, violate 15  U.S.C. §§ l692e and 1692g.   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).  19.  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.   2. The name of the creditor to whom the debt is owed;   20.  Some time prior to November 23, 2020, an obligation was allegedly  incurred to Swedish Hospital First Hill by Plaintiff.   21.  The Swedish Hospital First Hill obligation arose out of transactions in  which money, property, insurance or services which are the subject of the  transactions were primarily for personal, family or household purposes,  specifically medical services.   22.  The alleged Swedish Hospital First Hill obligation is a “debt” as  defined by 15 U.S.C. §1692a(5).   23.  Swedish Hospital First Hill is a “creditor” as defined by 15 U.S.C.  §1692a(4).   25.  Defendants collect and attempt 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 – November 23, 2020 Collection Letter   26.  On or about November 23, 2020, Defendant OOI sent Plaintiff an  initial collection letter (the “Letter”) regarding the alleged debt currently owed.  See Exhibit A.   28.  The letter states: “Unless you notify OOI within thirty (30) days after  receiving this notice that you dispute the validity of this debt, or any portion  thereof, this office will assume this debt is valid.  If you notify OOI in writing  within thirty (30) days from receiving this notice that you dispute the validity of  this debt, or any portion thereof, this office will obtain verification of the debt  or obtain a copy of a judgment and mail you a copy of such judgment or  verification. OOI shall provide you with the name and address of the original  creditor, if different from the current creditor, upon your request in writing to  this office within thirty (30) days after receiving this notice.”   29. Under 15 U.S.C. § 1692g(a)(5) the debt collector must provide a  statement that, upon the consumer's written request within the thirty-day  period, the debt collector will provide the consumer with the name and  address of the original creditor, if different from the current creditor.    3. A statement that unless the consumer, within thirty days  after receipt of the notice, disputes the validity of the debt,  or any portion thereof, the debt will be assumed to be valid  by the debt-collector;   31.  Defendant’s letter states that they will provide the name and address of  the original creditor if Plaintiff requests in writing, but continues that the  information regarding the creditor will be provided by Defendant within 30 days  after receiving the notice.   32.  The statement does not say that Defendant will provide the information  if Plaintiff’s written request is within 30 days of receipt of the notice as the law  requires, rather it states that upon written request (without specifying a time  period), the information will be provided within 30 days after receiving this  notice by Defendant.   33.  The 30-day time period is the time allowed for Plaintiff to make a  written request and not the amount of time in which Defendant is to provide the  information.   34.  This statement is false and deceptive because Defendant has no  obligation to provide the information requested within thirty days of receiving  the notice, rather the Plaintiff has thirty days to make the written request.   36.  A collection notice is deceptive when it can reasonably read to have  two or more different meanings one of which is inaccurate.   37.  The Defendants have failed to provide the consumer with a statutorily  compliant initial communication letter.   38.  Plaintiff has suffered an informational injury as she was not provided  with the information statutorily required to be included in the initial  communication letter from Defendant.   39.  As a result, Plaintiff could not make an informed decision regarding her  rights and options involving the alleged debt.   4. A statement that the consumer notifies the debt collector in  writing within thirty-day period that the debt, or any portion  thereof, is disputed, the debt collector will obtain  verification of the debt or a copy of a judgment against the  consumer and a copy of such verification or judgment will  be mailed to the consumer by the debt collector; and   40.  As a result of Defendant's deceptive, misleading and unfair debt  collection practices, Plaintiff has been damaged.  41.  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.   43.  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.   44.  Defendant violated said section by:   a. Making a false and misleading representation in violation of  §1692e(10).   45.  By reason thereof, Defendant is 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.  46.  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.   47.  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.   49.  The Defendant violated 15 U.S.C. §1692g, by not providing the  proper statutory discourses under §1692g.   50.   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.  