11.  Defendants allege Plaintiff owes a debt (“the Debt”).     12.  The Debt was primarily for personal, family or household purposes and is  therefore a “debt” as defined by 15 U.S.C. § 1692a(5).   13.  Sometime after the incurrence of the Debt Plaintiff fell behind on payments owed.    132. Plaintiff brings this action individually and as a class action on behalf of all  persons similarly situated in the State of New York from whom Defendants attempted to collect  a consumer debt using a collection letter substantially similar to the Letter herein, from one year  before the date of this Complaint to the present.   133. This action seeks a finding that Defendants' conduct violates the FDCPA, and  asks that the Court award damages as authorized by 15 U.S.C. § 1692k.  134. Defendants regularly engage in debt collection.  135. The Class consists of more than 35 persons from whom Defendants attempted to  collect delinquent consumer debts using a collection letter substantially similar to the Letter  herein.  136. Plaintiff's claims are typical of the claims of the Class.  Common questions of law  or fact raised by this class action complaint affect all members of the Class and predominate over  any individual issues. Common relief is therefore sought on behalf of all members of the Class.  This class action is superior to other available methods for the fair and efficient adjudication of  this controversy.  137. The prosecution of separate actions by individual members of the Class would  create a risk of inconsistent or varying adjudications with respect to the individual members of  the Class, and a risk that any adjudications with respect to individual members of the Class  would, as a practical matter, either be dispositive of the interests of other members of the Class  not party to the adjudication, or substantially impair or impede their ability to protect their  interests. Defendants have acted in a manner applicable to the Class as a whole such that  declaratory relief is warranted.  138. Plaintiff will fairly and adequately protect and represent the interests of the Class.  The management of the class action proposed is not extraordinarily difficult, and the factual and  legal issues raised by this class action complaint will not require extended contact with the  members of the Class, because Defendants' conduct was perpetrated on all members of the Class  and will be established by common proof.  Moreover, Plaintiff has retained counsel experienced  12  14.  Thereafter, at an exact time known only to Defendants, the debt was assigned or  otherwise transferred to Defendants for collection.    15.  In their efforts to collect the debt, Defendants contacted Plaintiff by letter (“the  Letter”) dated April 30, 2018. (“Exhibit 1.”)    16.  The letter was the initial communication Plaintiff received from Defendants.   17.  The letter is a “communication” as defined by 15 U.S.C. § 1692a(2).  18.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.    3  84.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     85.  As previously set forth, the Letter sets forth a “Current Balance Claimed Due.”    86.  As previously set forth, Plaintiff was always charged interest on any balance  carried on the account.   87.  As previously set forth, Plaintiff was always charged late fees on any payments  due but not timely made by Plaintiff.   88.  As previously set forth, Plaintiff was never informed by anyone that the terms and  conditions of the credit card were changed.   89.  The Letter fails to disclose whether the amount stated may increase due to  additional interest.   90.  The Letter fails to disclose whether the amount stated may increase due to  additional late fees.   91.  The Letter fails to indicate whether the creditor will accept payment of the  amount stated in full satisfaction of the debt if payment is made by a specified date.   8  Violation of 15 U.S.C. § 1692e   Violation of 15 U.S.C. § 1692g  Validation of Debts  9  Violation of 15 U.S.C. § 1692g  5  BARSHAY | SANDERSPLLC  Violation of 15 U.S.C. § 1692e  