)  Pursuant to 28 U.S.C. § 1746, Diane Rice, on behalf of Defendant General Revenue  Corporation, having first been duly sworn and upon oath, verifies, certifies, and declares  as follows:   1. I am the Director, Client Services & Account Management for the Defendant in  this civil proceeding, General Revenue Corporation.  I am a custodian of records  for General Revenue Corporation. I am familiar with General Revenue  Corporation’s processes and procedures.  If called as a witness in this matter, I  would be qualified to introduce records and information referred to in this  Answer.    2. I have read the above-entitled Answer prepared by attorneys for Defendant  General Revenue Corporation and all of the facts contained in it are true, to the  best of my knowledge, information, and belief formed after reasonable inquiry.   3. Numbered Paragraph 17 is true and correct, to the best of my knowledge,  information, and belief formed after reasonable inquiry.  General Revenue  Corporation did not set, establish, or otherwise take part in determining the  “Collection Cost Balance” referenced in Plaintiff’s Complaint.   Any violation of the FDCPA, which GRC denies, was not intentional and resulted,  if at all, from a bona fide error notwithstanding the maintenance of procedures  reasonably adapted to avoid such errors.   Plaintiff fails to state a claim upon which relief may be granted.   SECOND DEFENSE   Any violation of the law or damage suffered by Plaintiff, which GRC denies, was  due to the affirmative actions and/or omissions of Plaintiff or others, and does not give  rise to any liability of GRC. 