10.  Accordingly, on May 2, 2017, Mr. Dugger sent Verizon Wireless a letter,  via certified mail demanding that they cease collection of the Verizon debt, which was  discharged in Mr. Dugger’s bankruptcy.  A copy of this letter is attached as Exhibit F.   11.  Plaintiff’s bankruptcy is a matter of public record, is on his credit reports, is  in the files on the creditor, and is readily discoverable by any competent debt collector  via one of the bankruptcy “scrub” services.  In fact, on May 22, 2017, Defendant  Convergent pulled Mr. Dugger’s Experian credit report, which clearly lists his bankruptcy  upon it.  A portion of this credit report is attached as Exhibit G.    14.  All of Defendant Convergent’s collection actions at issue in this matter  occurred within one year of the date of this Complaint.   15.  Defendants’ collection communications are to be interpreted under the  “least sophisticated consumer” standard, see, Jeter v. Credit Bureau, 760 F.2d 1168,  1176 (11th Cir. 1985); LeBlanc v. Unifund CCR Partners, 601 F.3d 1185, 1193-1194  (11th Cir. 2010).  16.  Plaintiff adopts and realleges ¶¶ 1-15.   17.      Section 1692e of the FDCPA prohibits a debt collector from using any  false and/or any deceptive or misleading representation or means in connection with the  collection of a debt, including, but not limited to, the false representation of the   character, amount or legal status of any debt, see 15 U.S.C. § 1692e(2)(A).     18.  Demanding payment of a debt that is no longer owed, due to a  bankruptcy, is false and/or deceptive or misleading, in violation of § 1692e of the  FDCPA, see, Randolph v. IMBS, Inc., 368 F3d 726, 728-730 (7th Cir. 2004).    19.  Defendant Convergent’s violation of § 1692e of the FDCPA renders it  liable for actual and statutory damages, costs, and reasonable attorneys’ fees, see, 15  U.S.C. § 1692k.   21.  Section 1692c(c) of the FDCPA prohibits a debt collector from  communicating with a consumer after a direction to cease communications, and from  continuing to demand payment of a debt that the consumer has indicated that they  refuse to pay, see, 15 U.S.C. § 1692c(c).   22.  Here, the bankruptcy and the notices issued by that court (Exhibits B, C  and D), as well as Mr. Dugger’s letter to Defendant (Exhibit F) provided notice to cease  communications and cease collections.  By communicating regarding this debt and  demanding payment (Exhibit H), Defendant violated § 1692c(c) of the FDCPA.   23.  Defendant Convergent’s violation of § 1692c(c) of the FDCPA renders it  liable for actual and statutory damages, costs, and reasonable attorneys’ fees, see, 15  U.S.C. § 1692k.  24.  Plaintiff, Christopher Dugger, brings this action individually and as a class  action on behalf of all persons similarly situated in the State of Alabama from whom  Defendant attempted to collect a delinquent consumer debt, allegedly owed to Verizon  Wireless, which had been discharged in a bankruptcy, via the same form collection  letter that Defendant sent to Plaintiff (Exhibit H), from one year before the date of this  Complaint to the present.  This action seeks a finding that Defendant’s form letter  violates the FDCPA, and asks that the Court award damages as authorized by §  1692k(a)(2) of the FDCPA.   26.  The Class consists of more than 35 persons from whom Defendant  Convergent attempted to collect delinquent consumer debts by sending other  consumers the same form collection letter they sent Plaintiff Dugger.   27.  Plaintiff Dugger’s claims are typical of the claims of the Class.  Common  questions of law or fact raised by this class action complaint affect all members of the  Class and predominate over any individual issues.  Common relief is therefore sought  on behalf of all members of the Class.  This class action is superior to other available  methods for the fair and efficient adjudication of this controversy.   28.  The prosecution of separate actions by individual members of the Class  would create a risk of inconsistent or varying adjudications with respect to the individual  members of the Class, and a risk that any adjudications with respect to individual  members of the Class would, as a practical matter, either be dispositive of the interests  of other members of the Class not party to the adjudication, or substantially impair or  impede their ability to protect their interests.  Defendant has acted in a manner   applicable to the Class as a whole such that declaratory relief is warranted.   6.  On January 12, 2017, Mr. Dugger filed a Chapter 7 bankruptcy petition in  a matter styled In re: Dugger, N.D. AL. Bankr. No. 17-80117-CRJ7.  Among the debts  listed on Mr. Dugger’s Schedule F was a debt that he allegedly owed to Verizon  Wireless, see, attached as Exhibit B.       8.  On April 11, 2017, Mr. Dugger received a discharge of his debts, and on  April 13, 2017, Verizon Wireless was sent notice of this discharge via U.S. Mail, see, the  Certificate of Service to the Discharge of Debtor, which is attached as Exhibit D.   9.  On April 25, 2017 and April 26, 2017, Verizon Wireless sent Mr. Dugger  collection letters, demanding payment of the Verizon Wireless debt he allegedly owed  prior to the bankruptcy. Copies of these letters are attached as Group Exhibit E.   Violation Of § 1692e Of The FDCPA --  Demanding Payment Of A Debt That Is Not Owed    Violation Of § 1692c(c) Of The FDCPA --  Failure To Cease Communications And Cease Collections  