11.  Plaintiff Neuharth’s husband, Thomas Neuharth, allegedly entered into a  consumer transaction with “CITY OF S MILWAUKEE FIRE DEPT” ON January 27, 2016, for  ambulance transportation and associated medical services.    13.  On or about March 2, 2016, Plaintiff received a bill ostensibly from “CITY OF S  MILWAUKEE FIRE DEPT” (“SMFD”) regarding an alleged debt, allegedly owed to SMFD. A  copy of the letter is attached to this complaint as Exhibit A.   14.  Exhibit A is a bill for a call for ambulance services provided to Thomas Neuharth  by SMFD on January 27, 2016.   15.  Upon information and belief, Exhibit A is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   16.  Upon information and belief and the investigation of counsel, Lifequest mailed  Exhibit A to Plaintiff. Exhibit A includes Lifequest’s address in Wautoma, Wisconsin.   17.  On or about March 25, 2016, Plaintiff received a bill ostensibly from SMFD,  regarding another alleged debt.  A copy of the letter is attached to this complaint as Exhibit B.   18.  Upon information and belief, Exhibit B is a bill for a call for ambulance services  provided to Thomas Neuharth by SMFD on November 7, 2015.   19.  Upon information and belief, Exhibit B is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   20.  Upon information and belief and the investigation of counsel, Lifequest mailed  Exhibit B to Plaintiff. Exhibit B includes Lifequest’s address in Wautoma, Wisconsin.   21.  Neither Exhibit A nor Exhibit B include the names “Lifequest” or “Life Line.”   22.  On or about April 24, 2016, Plaintiff received a bill from Lifequest regarding the  same alleged SMFD debt referenced in Exhibit A. A copy of the letter is attached to this  complaint as Exhibit C.   23.  Exhibit C states that the sender is "LifeQuest Services."   24.  Exhibit C also purports to be a debt collection letter.   26.  Exhibit C also contains both the validation notice required by 15 U.S.C. §  1692g(a) and the notice required by 15 U.S.C. § 1692e(11):  ...   27.  On or about April 24, 2016, Plaintiff received a bill from Lifequest regarding the  same alleged SMFD debt referenced in Exhibit B. A copy of the letter is attached to this  complaint as Exhibit D.   28.  Exhibit D is virtually identical to Exhibit C, except for the date of the ambulance  services. Like Exhibit C, Exhibit D appears to be a debt collection letter.     29.  Even if LifeQuest was billing for SMFD before the debt was in default, LifeQuest  is a debt collector as a matter of law with respect to Exhibits A-D, regardless of which name it  was using. 15 U.S.C. § 1692a(6) (“the term [debt collector] includes any creditor who, in the  process of collecting his own debts, uses any name other than his own which would indicate that  a third person is collecting or attempting to collect such debts.”); Catencamp v. Cendant  Timeshare Resort Group -- Consumer Finance, Inc., 471 F.3d 780, 782 (7th Cir. 2006).   31.  In fact, LifeQuest created and mailed bills, including Exhibits A and B, in the  name of SMFD.   32.  The purpose of using SMFD’s name on letters formatted as “bills” and then using  LifeQuest’s name on subsequent communications formatted as “debt collection letters” is to  deceive consumers into believing that a new debt collection agency is collecting the account  when the status of the debt has not actually changed. Consumers are more concerned and upset  by contacts from debt collectors than from original creditors or their billing services.   33.  Plaintiff Neuharth was confused by Exhibits A-D.   34.  Neuharth had to spend time and money investigating Exhibits A-D, and the  consequences of any potential responses to Exhibits A-D.   35.  The FDCPA presumes that violations cause injury to consumers, and that such  injuries are concrete and particularized but difficult to quantify. For this reason, and to encourage  consumers to bring FDCPA actions, Congress authorized an award of statutory damages for  violations. 15 U.S.C. § 1692k(a).   36.  Moreover, Congress has explicitly described the FDCPA as regulating “abusive  practices” in debt collection. 15 U.S.C. §§ 1692(a) – 1692(e). Any person who receives a debt  collection letter containing a violation of the FDCPA is a victim of abusive practices. See 15  U.S.C. §§ 1692(e) (“It is the purpose of this subchapter to eliminate abusive debt collection  practices by debt collectors, to insure 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”).   38.  Likewise, Exhibit D also states:   39.  Exhibits C and D threaten to collect “Interest.”   40.  Upon information and belief, Exhibits C and D falsely state or imply that  LifeQuest has a right to collect interest on consumers’ alleged debts.   41.  Further, upon information and belief, neither Defendant nor SMFD has any legal  basis to add interest to the Plaintiff’s and Class Members’ alleged debts.   43.  Upon information and belief, Exhibits C and D are threatening to collect  prejudgment interest, despite the fact that no legal action has been initiated against the consumer.   44.  A debt collector cannot collect prejudgment interest when that interest has not been  awarded by a court or agreed to by contract. Paige v. Waukesha Health Sys., No. 12-cv-601-CNC;  2013 U.S. Dist. LEXIS 96962, *18-20 (“Wisconsin cases suggest, as the Paiges argue, that absent  a contractual agreement prejudgment interest cannot be automatically added by a creditor but  instead must await a court judgment;”), citing Estreen v. Bluhm, 79 Wis. 2d 142, 156, 255  N.W.2d 473, 482 (1977); Erickson by Wightman v. Gundersen, 183 Wis. 2d 106, 123, n.8, 515  N.W.2d 293, 301, n.8 (Ct. App. 1994); Beacon Bowl, Inc. v. Wis. Elec. Power Co., 176 Wis. 2d  740, 776-77, 501 N.W.2d 788, 802-03 (1993); see also Veach v. Sheeks, 316 F.3d 690, 692 (7th  Cir. 2003); contra Trease v. Tri-State Adjustments, Inc., 934 F. Supp. 2d 1016 (E.D. Wis. 2013).   45.  The alleged debts in Exhibits C and D have not been reduced to judgment, and  Neuharth has never been sued to collect this alleged debt.   46.  Neither Plaintiff Neuharth nor her deceased husband ever agreed to any contract  specifying a contractual amount or rate of interest, with SMFD or Defendant.  Lindenbach letters   47.  Plaintiff Lindenbach allegedly entered into a consumer transaction with “CITY  OF WEST ALLIS FIRE DEPT” for ambulance transportation and associated medical services.    49.  Upon information and belief, Exhibit E is a form letter, generated by computer,  and with the information specific to Plaintiff inserted by computer.   50.  Exhibit E states the following:   51.  Exhibit E also states:   52.  LifeQuest’s threat to collect the debt through tax intercept was false.   53.  Lindenbach filed a Wisconsin Homestead Credit Claim for 2015 with the  Wisconsin Department of Revenue on or around February 1, 2016.   54.  Lindenbach received his homestead credit in full about one week later. None of  the credit was intercepted.   56.  Upon information and belief, it is common practice in the debt collection industry  for letters containing references to tax intercepts to be sent to consumers during the period when  most consumers are preparing and filing tax returns. The threats are intended to scare consumers  into making payments to avoid tax refund intercepts.    57.  Exhibit E also threatens to collect “Interest.”   58.  Upon information and belief, Exhibit E falsely states or implies that LifeQuest has  a right to collect interest on consumers’ alleged debts.   59.  Further, upon information and belief, neither Defendant nor “City of West Allis  Fire Dept” has any legal basis to add interest to the Plaintiff’s and Class Members’ alleged debts.   60.  Although the amount of “Interest” in Exhibit E is $0.00, the unsophisticated  consumer would believe that the letter implies that interest could be added to the debt in the  future. See, eg. Tylke v. Diversified Adjustment Serv., No. 14-cv-748; 2014 U.S. Dist. LEXIS  153281, *7 (E.D. Wis. Oct. 28, 2014) (“the inclusion of a collection fee, even one showing a  balance of zero, could imply the future possibility of one.”).   61.  Upon information and belief, Exhibit E is threatening to collect prejudgment  interest, despite the fact that no legal action has been initiated against the consumer.   63.  The alleged debt in Exhibit E has not been reduced to judgment, and Lindenbach  has never been sued to collect this alleged debt.   64.  Lindenbach has never agreed to any contract specifying a contractual amount or  rate of interest, with the City of West Allis Fire Department or Defendant.  The FDCPA and WCA   65.  15 U.S.C. § 1692e generally prohibits “any false, deceptive, or misleading  representation or means in connection with the collection of any debt.”    66.  15 U.S.C. § 1692e(2) specifically prohibits the “false representation of the  character,  amount, or legal status” of an alleged debt, or the “false representation  of…compensation which may be lawfully received by any debt collector for the collection” of an  alleged debt.   67.  15 U.S.C. § 1692e(5) specifically prohibits threatening “to take any action that  cannot legally be taken or that is not intended to be taken.”   68.  15 U.S.C. § 1692e(10) specifically prohibits the “use of any false representation  or deceptive means to collect or attempt to collect any debt.”   70.  15 U.S.C. § 1692f(1) specifically prohibits the “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.”    71.  Wis. Stat. § 427.104(1)(j) specifically prohibits a debt collector from  “[c]laim[ing], or attempt[ing] or threaten[ing] to enforce a right with knowledge or reason to  know that the right does not exist.”   72.  Wis. Stat. § 427.104(1)(L) also specifically prohibits a debt collector from  “[t]hreaten[ing] action against the customer unless like action is taken in regular course or is  intended with respect to the particular debt.”  73.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   74.  Count I is brought on behalf of Plaintiff Neuharth.   75.  LifeQuest’s use of SMFD’s name to send bills, prior to sending debt collection  letters under LifeQuest’s own name, was confusing and misleading to the unsophisticated  consumer.   76.  The unsophisticated consumer would believe that a new collection agency was  collecting the consumer’s account.   77.  In fact, LifeQuest was still collecting the debt.   78.  LifeQuest violated 15 U.S.C. §§ 1692e, 1692e(2)(a) and 1692e(10).  80.  Count Ii is brought on behalf of Plaintiff Lindenbach.   81.  LifeQuest falsely stated that Plaintiff’s debt would be collected through the State  Tax Refund Intercept Program.   82.  In fact, none of Plaintiff’s homestead credit refund was intercepted, despite  Plaintiff’s filing for the credit two months after the date printed on Exhibit E.   83.  LifeQuest violated 15 U.S.C. §§ 1692e and 1692e(10).  84.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   85.  Count III is brought on behalf of both Plaintiffs.   86.  The inclusion of “Interest” in Exhibits C, D and E is a false, deceptive, and/or  misleading representation to the unsophisticated consumer recipient.  LifeQuest has no legal  basis for collecting interest on Plaintiffs’ alleged debts.    87.  The unsophisticated consumer would believe, or at a minimum would be  confused, whether he may owe interest in the future for the alleged debt. There is no legitimate  reason for the “Interest” field to be on the letter other than to make the consumer believe that the  number will increase.   88.  Exhibits C, D and E also falsely represent that Defendant is lawfully entitled to  collect interest.   90.  Exhibits C, D and E create a false impression as to its authorization or approval  for collecting interest.   91.  Defendant violated 15 U.S.C. §§ 1692e, 1692e(2), 1692e(5), and 1692e(10).  92.  Plaintiffs incorporate by reference as if fully set forth herein the allegations  contained in the preceding paragraphs of this Complaint.   93.  Exhibits C, D and E claim, attempt, or threaten to enforce a right to interest, even  though Defendant knew, or should have had reason to know, that no such right existed at the  time the letter was sent.   94.  Defendant violated Wis. Stat. §§ 427.104(1)(j) and 427.104(1)(L).  95.  Plaintiffs bring this action on behalf of three classes.   96.  Class 1 is defined as (a) all natural persons in the State of Wisconsin (b) who were  sent a communication in the form of Exhibit A or B to the complaint in this action, (c) seeking to  collect a debt for personal, family or household purposes, (d) and who were subsequently sent a  collection letter in the form of Exhibit C or D to the complaint in this action, (e) on or after  August 22, 2015, (f) that was not returned by the postal service.    98.  Class 3 is defined as (a) all natural persons in the State of Wisconsin (b) who were  sent a communication in the form of Exhibit E to the complaint in this action, (c) seeking to  collect a debt for personal, family or household purposes, (d) and whose next tax refund or  homestead credit refund were not intercepted, (e) on or after August 22, 2015, (f) that was not  returned by the postal service.   99.  Each Class is so numerous that joinder is impracticable. Upon information and  belief, there are more than 50 members of each Class.  100.  There are questions of law and fact common to the members of each class, which  common questions predominate over any questions that affect only individual class members.   The predominant common question is whether Exhibits A-D violate the FDCPA and/or the  Neuharth letters  