15. At all times relevant, Plaintiff was an individual residing within the State of  Nevada.   16. At all times relevant, Defendant conducted business in the State of Nevada.   17. On or about December 20, 2010, Plaintiff allegedly entered into a gym  membership agreement, and at some point thereafter fell behind on the  payments. This debt was money, property, or their equivalent, which is due  or owing, or alleged to be due or owing, from a natural person to another  person and were therefore “debt(s)” and a “consumer debt” as the terms are  defined by 15 U.S.C. § 1692(a)(6).   18. Plaintiff takes no position as to the validity of the alleged debt.   19. Subsequently, the alleged debt was allegedly assigned, placed or otherwise  transferred, to Defendant for collection.   20. On or about August 21, 2014, Defendant or its agent/s began contacting  Plaintiff via written letter (the “letter”) in attempt to collect the alleged debt.  This letter was a “communications” as defined in 15 U.S.C. § 1692(a)(2).   47. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (the “Class”).   VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT  15 U.S.C. §§ 1692-1692(P) (FDCPA)  • an award of statutory damages of $1,000.00 to each named Plaintiff,  pursuant to 15 U.S.C. § 1692k(a)(2)(A), against Defendant;  • an award of any such amount as the court may allow for all other class  members, not to exceed the lesser of $500,000 or 1 per centum of the net  worth of each Defendant, pursuant to 15 U.S.C. § 1692k(a)(2)(B), against  Defendant;  • an award of costs of litigation and reasonable attorney’s fees, pursuant to  15 U.S.C. § 1692k(a)(3), against Defendant; and  • any other relief the Court may deem just and proper. 