13.  Plaintiff brings this action as a state wide class action, pursuant to Rule 23 of the  Federal Rules of Civil Procedure (hereinafter “FRCP”), on behalf of himself and all Kansas  consumers and their successors in interest (the “Class”), who have received debt collection  letters, and/or notices from the Defendants which are in violation of the FDCPA, as described in  this Complaint.   14.  This Action is properly maintained as a class action. The Class consists of:   All Kansas consumers who received collection letters and/or notices from the  Defendants that contained at least one of the alleged violations arising from  the Defendants’ violation of 15 U.S.C. § 1692 et seq.   The Class period begins one year prior to the filing of this action.   16.  On or before April 1, 2013, Plaintiff’s alleged account with Emergency Services  of Kan became past due and was in default.   18.  On or before April 1, 2013, Emergency Services of Kan placed Plaintiff’s alleged  account with HRRG for the purpose of collection.   19.  On or before April 1, 2013, HRRG caused to be mailed to Plaintiff a letter  attempting to collect the alleged debt. A copy of said letter is annexed hereto as Exhibit A.   20.  Said letter requested payment in full.   21.  Said letter stated in part, “If we can answer any questions, or if you feel you do  not owe this amount, please call us toll free at 800-984-9115 or write us at the above address.”  [Bold emphasis added.]   22.  Upon receipt Plaintiff read said letter.   23.  Pursuant to the FDCPA, a dispute of a debt must be in writing to cease collection  of the debt until the debt is verified by the debt collector.  15 U.S.C. § 1692g(b).   24.  Defendant produced and mailed said letter to Plaintiff after a letter containing the  same language was found by the United States Court of Appeals for the Third Circuit to violate  the FDCPA in an opinion filed March 1, 2013. Caprio v. Healthcare Revenue Recovery Grp.,  LLC, 709 F.3d 142 (3d Cir. 2013).  25.  Plaintiff repeats the allegations contained in paragraphs 1 through 24 as if the  same were here set forth at length.   27.  Section 1692g of the FDCPA requires the debt collector to give what is  commonly referred to as a thirty-day (30) notice within five (5) days of its communication with  the consumer.   28.  Section 1692g(a)(3),(4),(5) of the FDCPA requires the debt collector:  Within five days after the initial communication with a  consumer in connection with the collection of any  debt…send the consumer a written notice containing ---  (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 --- (4) a statement that if  the consumer notifies the debt collector in writing within  the 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 --- (5) 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.   29.  HRRG’s letter to Plaintiff, dated April 1, 2013 contained the required validation  notice on the back of the letter.   30.  The second paragraph of HRRG’s letter to Plaintiff, dated April 1, 2013, states in  its entirety, “If we can answer any questions, or if you feel you do not owe this account, please  call us toll free at 800-984-9115 or write us at the above address.  This is an attempt to collect a  debt.  Any information obtained will be used for that purpose.  (NOTICE: SEE REVERSE SIDE  FOR IMPORTANT INFORMATION.)”  [Bold emphasis added.]   32.  Upon reading paragraph two of the notice from HRRG, the least sophisticated  consumer would believe that he should choose either of the instructions as set forth in the second  paragraph of the notice and either call the toll free number or write to HRGG at the address on  the letter, to dispute the alleged debt.   33.  Pursuant to the FDCPA, a dispute of a debt must be in writing to cease collection  of the debt until the debt is verified by the debt collector.  15 U.S.C. § 1692g(b).   34.  HRRG violated Section 1692g et seq. of the FDCPA by providing instructional  language which is confusing and makes the least sophisticated consumer uncertain as to what he  must do to properly dispute the alleged debt.   35.  By reason thereof, Defendants are liable to Plaintiff for declaratory judgment that  Defendants’ conduct violated Section 1692g et seq., of the FDCPA, statutory damages, costs and  attorneys’ fees.  36.  Plaintiff repeats the allegations contained in paragraphs 1 through 35 as if the  same were here set forth at length.   37.  Section 1692e(10) of the FDCPA prohibits the use of any false representation or  deceptive means to collect or attempt to collect any debt.   FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. § 1692  VIOLATION OF 15 U.S.C. § 1692e(10)   FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. § 1692  VIOLATION OF 15 U.S.C. § 1692g(a)(5)  