13.  On or about May 9, 2016, Plaintiff entered into an Apartment Rental  Contract (the “Contract”) with Hamilton Point Property Management, LLC  (“Hamilton”), a Delaware limited liability company, the subject of which was a  rental apartment at Creekside Corners in Lithonia, Georgia.   15.  In December 2016, due to flooding in Plaintiff’s Creekside Corners  apartment, Plaintiff refused to pay rent of $760 per month. In response, Hamilton  retained Defendants to file a Dispossessory Warrant in the Magistrate Court of  DeKalb County demanding removal of Plaintiff from his apartment as well as  money damages for unpaid rent, late fees, and other associated costs and fees.   16.  While the Judge did grant the landlord possession in that case with a  writ of possession to issue January 18, 2017 and a money judgment in the amount  of $600, the Judge also gave Plaintiff a large offset of the rent that was being  demanded.   17.  Plaintiff has appealed that ruling and paid the money judgment into  the registry of the Court and is currently in possession of the apartment as the  eviction has been stayed.    18.  Williams, a licensed attorney, acting within his scope of employment  with Fowler and as lead attorney for Hamilton, filed the Dispossessory Warrant.   19.  Included in the Dispossessory Warrant filed by Williams was a  demand for late fees which exceeded the amount stated in the Contract.   21.  Had Defendants undertaken even a cursory review of the late fees  demanded in the Dispossessory Warrant[s] prior to filing, they would have realized  that the warrant[s] demanded excessive late fees. It would appear, instead, that  Defendants merely act as a “rubber stamp” for the landlord, demanding the court  grant the requested relief without undertaking any meaningful review of the  warrant.  29.  Plaintiff incorporates the paragraphs 1-26 as if fully set forth herein.   30.  Section 1692e prohibits “false, deceptive, or misleading” behavior,  including using “false representation or deceptive means to collect or attempt to  collect any debt.” Bishop v. Ross Earle & Bonan, PA, 817 F.3d 1268 (11th Cir.  2016).   31.  More specifically, §1692e(2)(A) prohibits “the false representation of  the character, amount, or legal status of any debt.” “Even an unintentional  misrepresentation violates [15 U.S.C. § 1692e(2)(A)].” Berndt v. Fairfield Resorts,  Inc., 337 F.Supp.2d 1120, 1131 (W.D.Wis.2004).   33.  Plaintiff incorporates the paragraphs 1-26 as if fully set forth herein.   34.  Section 1692e prohibits “false, deceptive, or misleading” behavior,  including using “false representation or deceptive means to collect or attempt to  collect any debt.” Bishop v. Ross Earle & Bonan, PA, 817 F.3d 1268 (11th Cir.  2016).   35.  More specifically, §1692e(3) stands for the premise that if there has  been no individualized review of a debtor's case, a communication from that  attorney is considered false and misleading for purposes of the FDCPA.  Newman  v. Checkrite California, Inc., 912 F. Supp. 1354, 1382 (E.D. Cal. 1995).   37.  By filing the Dispossessory Warrant without first reviewing the  Plaintiff’s account, Defendants engaged in “false, deceptive, or misleading”  behavior, in direct violation of 15 U.S.C. § 1692e(2)(A). As consequence, Plaintiff  is entitled to recover statutory damages, attorney’s fees, and costs of court from  Defendants in an amount to be determined at trial.  38.  Plaintiff incorporates the paragraphs 1-26 as if fully set forth herein.   39.  Section 1692f prohibits unfair or unconscionable means of collection.  Subsection (1) of this section specifically prohibits “collection of any amount  (including any interest, fee, charge, or expense incidental to the principal  obligation) unless such amount is expressly authorized by the agreement creating  the debt or permitted by law.” 15 U.S.C. § 1692f(1). Bradley v. Franklin  Collection Service, Inc., 739 F.3d 606, 609 (11th Cir. 2014).   41.  By falsely claiming in the Dispossessory Warrant that Plaintiff owed  more in late fees than he actually did, Defendants engaged in an “unfair or  unconscionable means of collection”,  in direct violation of 15 U.S.C. § 1692f(1).  As consequence, Plaintiff is entitled to recover statutory damages, attorney’s fees,  and costs of court from Defendants in an amount to be determined at trial.  42.  Plaintiff incorporates the paragraphs 1-34 as if fully set forth herein.   43.  As stated above, § 1692f prohibits the use of any unfair or  unconscionable means to collect or attempt to collect any debt. It also provides a  non-exhaustive list of behavior that would violate of the section. Its purpose is to  enable the courts, where appropriate, to proscribe improper conduct which is not  specifically addressed.    45.  An attorney filing a lawsuit without giving any meaningful review to  the account in question is a violation of § 1692f.  See e.g., Johnson v. Law Offices  of Farrell and Seldin, Civ. No. 12-0877 MV/RHS (D.N.M. Mar. 29, 2013). As  consequence, Plaintiff is entitled to recover statutory damages, attorney’s fees, and  costs of court from Defendants in an amount to be determined at trial.  46.  Upon information and belief, during the one year immediately  preceding the filing of this action, Defendants filed at least one hundred (100)  Dispossessory Warrants against the tenants, including Plaintiff all of which sought  late fees in excess of the contractual amount and were, in effect, rubber-stamped by  Defendants without meaningful review.   47.  Accordingly, Plaintiff brings this action on behalf of a class of  similarly situated individuals, pursuant to Federal Rules of Civil Procedure 23(a)  and 23(b)(3).   49.  The identities of all class members are readily ascertainable from the  DeKalb County public court records, Hamilton’s records (which are subject to  subpoena), as well as Defendants’ records, since, as attorneys at law, Defendants  are expected to maintain such records.   50.  Numerosity. Plaintiff is informed and believes, and on that basis  alleges that the Class described above is so numerous that joinder of all members  would be impracticable. On information and belief, there are at least 100 members  in the Class.   51.  Common Questions Predominate. Common questions of law and  fact exist as to all members of the Plaintiff Class and those questions predominate  over any questions or issues involving only individual class members. The  principal issue is whether Defendants repeatedly and systematically filed  Dispossessory Warrants which sought excessive late fees.   52.  Typicality. Plaintiff’s claims are typical of the claims of the class  members. Plaintiff and all members of the Plaintiff Class have claims arising out of  Defendant’s common uniform course of conduct complained of herein.   54.  Superiority. The FDCPA explicitly permits class action suits.  Jerman, at 1631. A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a single  forum efficiently and without unnecessary duplication of effort and expense that  individual actions would engender.   False Representation in Connection  With Debt Collection Activities  (Ref. 15 U.S.C. § 1692e)   False Representation in Connection  With Debt Collection Activities  (Ref. 15 U.S.C. § 1692e)   Unfair Practices in Connection  With Debt Collection Activities  (Ref. 15 U.S.C. § 1692f)   Unfair Practices in Connection  With Debt Collection Activities  (Ref. 15 U.S.C. § 1692f)  