12.  Plaintiff brings these claims on behalf of the following class pursuant to Rule 1708  of Pennsylvania Civil Procedure.  The Class consists of all individuals to whom Defendant enrolled in  automatic payment schemes without their prior authorization or  consent in an attempt to collect upon any debt.   13.  Excluded from the class is Defendant HH&L as well as their past and present  officers, employees, agents or affiliates, any judge who presides over this action, and any attorneys  who enter their appearance in this action.   14.  Plaintiff reserves the right to expand, limit, modify, or amend the class definitions,  including the addition of one or more subclasses, in connection with his motion for class  certification, or at any other time, based on, among other things, changing circumstances and new  facts obtained during discovery.   16.  This action has been brought, and may properly be maintained, as a class action  pursuant to the provisions of Rule 23 of the Federal Rules of Civil Procedure because of a well- defined public interest in this litigation:   17.  Numerosity – Federal Rule of Civil Procedure 23(a)(1).  Upon information and  belief, the members of Class are so numerous that individual joinder of all class members is  impracticable because there are hundreds and/or thousands of persons where Defendant has  utilized the abovementioned false, deceptive, unfair, and unconscionable means in an attempt to  collect a debt.   18.  The identities of all class members are readily ascertainable from the records of  Defendant and those individuals to whom Defendant has enrolled in automatic payment schemes  without their prior knowledge, consent, or authorization.    19.  Commonality – Federal Rule of Civil Procedure 23(a)(2). This action involves  questions of law and fact that are common to the class members. Such common questions include,  but are not limited to:  a. Whether Defendant’s actions of enrolling Plaintiff in an automatic payment  scheme without their prior knowledge, authorization or consent constituted a  false and deceptive means in an attempt to collect a debt in violation of 15  U.S.C. §§ 1692e(5) and 1692e(10) of the FDCPA.   21.  Adequacy of Representation – Federal Rule of Civil Procedure 23(a)(4).  Plaintiff is an adequate representative of the Class because their interests do not conflict with the  interests of the other class members Plaintiff seeks to represent; Plaintiff has retained counsel  competent and experienced in complex class action litigation; Plaintiff intends to prosecute this  action vigorously; and Plaintiff’s counsel has adequate financial means to vigorously pursue this  action and ensure the interests of the classes will not be harmed. Furthermore, the interests of the  class members will be fairly and adequately protected and represented by Plaintiff and Plaintiff’s  counsel.   22.  Plaintiff incorporates the allegations contained in the paragraphs, above, as if fully  set forth at length herein.   23.  There is abundant evidence of the use of abusive, deceptive, and unfair debt  collection practices by many debt collectors. Abusive debt collection practices contribute to the  number of personal bankruptcies, to marital instability, to the loss of jobs, and to invasions of  individual privacy. 15 U.S.C. 1692(a).   24.  The purpose of the FDCPA is to “eliminate abusive debt collection practices by  debt collectors, to ensure that those debt collectors who refrain from using abusive debt collection  practices are not competitively disadvantaged, and to promote consistent State action to protect  consumers against debt collection abuses.” 15 U.S.C. § 1692(e).   25.  Jimmie Hilliard is a “consumer” as defined by § 1692a(3) of the FDCPA.   26.  HH&L is a “debt collector” as defined by § 1692a(6) of the FDCPA.   28.  The Third Circuit has held that the FDCPA is to be enforced by private attorney  generals. Weiss v. Regal Collections, 385 F.3d 337, 345 (3d. Cir. 2004).   29.     Section 1692e of the FDCPA provides:  A debt collector may not use any false, deceptive, or misleading  representation or means in connection with the collection of any  debt. Without limiting the general application of the foregoing, the  following conduct is a violation of this section:  …  (10) The use of any false representation or deceptive means to  collect or attempt to collect any debt or to obtain information  concerning a consumer.  15 U.S.C. § 1692e of the FDCPA.   30.  On August 5, 2019, September 10, 2019, September 24, 2019, October 30, 2019,  December 10, 2019, and January 8, 2020, HH&L, Mr. Hilliard made $30.00 payments to HH&L  in order to settle the abovementioned debt. See Exhibit “B”.    31.  On January 16, 2020, Jimmie Hilliard discovered that HH&L had enrolled him in  an automatic payment scheme without Mr. Hilliard’s prior knowledge, authorization or consent.   33.  Section 1692d of the FDCPA provides, in relevant part: “A debt collector may not  engage in any conduct the natural consequence of which is to harass, oppress, or abuse any person  in connection with the collection of a debt.”    34.  Here, the only natural consequence of HH&L’s acts of willfully communicating  credit information which was known to be false was to harass, oppress, and abuse Jimmie Hilliard.    35.  As such, HH&L’s conduct, as set forth above, violated 15 U.S.C. § 1692d of the  38.  Plaintiff incorporates the allegations contained in the paragraphs, above, as if fully  set forth at length herein.   40.  The party need not establish either irreparable harm or immediate relief and a court  “may issue a final injunction if such relief is necessary to prevent a legal wrong for which there is  no adequate redress at law.” Berwick Twp. v. O’Brien, 148 A.3d 872, 891 (Pa. Commw. Ct. 2016)  citing Buffalo Twp. at 663.    41.  A party must also show greater injury will result from refusing rather than granting  the relief requested. Berwick Twp. v. O'Brien, 148 A.3d 872, 891 (Pa. Commw. Ct. 2016).   42.  In the case at hand, Plaintiff possesses clear rights to relief through §§ 1692d,  1692e(5), 1692e(10), and 1692k of the FDCPA.    43.  HH&L affirmatively employed false and misleading representations in clear  violation of the FDCPA by enrolling Mr. Hilliard in an autopayment scheme without his prior  knowledge, authorization or consent.    44.  This course of conduct constituted a false and misleading representation in  connection with the collection of any debt thus violating §§ 1692e, 1692e(5), 1692e(10), and  1692d of the FDCPA.   45.  In the case at hand, a permanent injunction is necessary to prevent the legal  wrongdoing of HH&L.    5.  On July 17, 2019, Midland Funding, through HH&L, filed a Civil Complaint  against Jimmie Hilliard in Magisterial District Court at Docket Number: MJ-38125-CV-0000114- 2019. A true and correct copy of the Docket is attached hereto, made a part hereof, and marked as  Exhibit “A”.   6.  On September 5, 2019, a Civil Action Hearing was held before the Honorable  James Gallagher, Magisterial District Judge. See Exhibit “A”.    7.  On September 10, 2019, at the conclusion of the Civil Action hearing, Judge  Gallagher granted a JUDGMENT FOR PLAINTIFF in favor of Capital One Bank and against  Jimmie Hilliard. See Exhibit “A”.    8.  On September 24, 2019, Jimmie Hilliard began making monthly payments to  HH&L in order to settle the abovementioned  alleged objection.  A true and correct copy of Jimmie  Hilliard’s online banking statement is attached hereto, made a part hereof, and marked as Exhibit  PERMANENT INJUNCTION ENJOINING   THE LAW OFFICES OF HAYT, HAYT, OF LANDAU FROM  CREATING FALSE AUTOPAYMENT ARRANGEMENT   VIOLATIONS OF THE FDCPA, 15 U.S.C. § 1692, et seq.  