14. Plaintiff brings this claim on behalf of the following class, pursuant to Fed. R. Civ. P.  23(a) and 23(b)(3).   16. The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf it attempts to collect and/or has  purchased debts.   17. Excluded from the Plaintiff Class are the Defendants and all officers, members, partners,  managers, directors and employees of the Defendants and their respective immediate families, and  legal counsel for all parties to this action, and all members of their immediate families.    18. There are questions of law and fact common to the Plaintiff Class, which common issues  predominate over any issues involving only individual class members. The principal issue is whether  the Defendants’ written communications to consumers, in the form attached as Exhibit A, violate  15 U.S.C. §§ 1692e and 1692f.   19. The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the Plaintiff  Class defined in this complaint. The Plaintiff has retained counsel with experience in handling  consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiff nor her attorneys  have any interests, which might cause them not to vigorously pursue this action.   22. Depending on the outcome of further investigation and discovery, Plaintiff may, at the  time of class certification motion, seek to certify a class(es) only as to particular issues pursuant to  Fed. R. Civ. P. 23(c)(4).  23. Plaintiff repeats the above allegations as if set forth here.   24. Some time prior to May 10, 2021, Plaintiff allegedly incurred an obligation to non-party  Odessa Physician Assoc PL (“Odessa”).   25. The obligation arose out of transactions incurred primarily for personal, family, or  household purposes, specifically medical services.    26. The alleged Odessa obligation is a "debt" as defined by 15 U.S.C.§ 1692a (5).   27. Odessa is a "creditor" as defined by 15 U.S.C.§ 1692a (4).   28. According to Defendants’ letter, Cascade is the current creditor of the Odessa debt.   29. Cascade collects and attempts to collect debts incurred or alleged to have been incurred  for personal, family or household purposes on behalf of itself or other creditors using the United  States Postal Services, telephone and internet.   30. Cascade is a debt buyer.   31. Cascade purchases or otherwise acquires consumer debt from creditor(s).   32. Cascade then collects the consumer debt, hires a third party to collect the consumer debt,  or hires an attorney to pursue collection litigation in connection with the consumer debt.   33. Debt Recovery was collecting the Odessa account on behalf of Cascade.   35. Debt Recovery collects and attempts to collect debts incurred or alleged to have been  incurred for personal, family or household purposes on behalf of creditors using the United States  Postal Services, telephone and internet.  Violation – May 10, 2021 Collection Letter   36. On or about May 10, 2021, Defendants sent Plaintiff a collection letter regarding the  alleged debt.  See Letter attached as Exhibit A.    37. The letter states that “The law limits how long you can be sued on a debt. Because of the  age of your debt, the current creditor cannot sue you for it.”    38. The letter further states, “Should you choose to make a payment for less than the discount  offer it may be considered a partial payment and may re-start the statute of limitations”.   39. This statement is false, since under applicable law, the statute of limitations on the  alleged debt cannot be restarted by making a payment at all. See, Tex. Fin. Code Ann. § 392.307(d).   40. Plaintiff was misled as to her rights.   41. Plaintiff was misled into believing that making a partial payment or promise to pay could  restart the statute of limitation.   42. Plaintiff could have made a partial payment to reduce the balance without fear that doing  so would restart the statute of limitations.   43. Plaintiff was prevented from acting this way due to Defendants’ improper statements in  the Letter.   44. Defendants’ actions were false, deceptive, and/or misleading.   45. Plaintiff would have pursued a different course of action were it not for Defendants’  violations.   47. Plaintiff was therefore unable to evaluate her options of how to handle this debt.   48. Because of this, Plaintiff expended time, money, and effort in determining the proper  course of action.   49. Plaintiff was hesitant to make a partial payment due in part to Defendants’ false claim  that such a payment would restart the statute of limitation.   50. In addition, Plaintiff suffered emotional harm due to Defendants’ improper acts.   51. These violations by Defendants were knowing, willful, negligent and/or intentional, and  the Defendants did not maintain procedures reasonably adapted to avoid any such violations.   52. Defendants’ collection efforts with respect to this alleged debt from Plaintiff caused  Plaintiff to suffer concrete and particularized harm, inter alia, because the FDCPA provides Plaintiff  with the legally protected right to be not to be misled or treated unfairly with respect to any action  for the collection of any consumer debt.   53. Defendants’ deceptive, misleading and unfair representations with respect to its  collection efforts were material misrepresentations that affected and frustrated Plaintiff's ability to  intelligently respond to Defendants’ collection efforts because Plaintiff could not adequately  respond to Defendants’ demand for payment of this debt.   54. Defendants’ actions created an appreciable risk to Plaintiff of being unable to properly  respond or handle Defendants’ debt collection.   55. Plaintiff was confused and misled to her detriment by the statements in the dunning letter,  and relied on the contents of the letter to her detriment.   57. Plaintiff repeats the allegations above as if set forth here.   58. Defendants’ debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   59. Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   60. Defendants violated said section as described above, by making false or misleading  representations in violation of §§ 1692e, 1692e (2)(A), 1692e (5) & 1692e (10).   61. By reason thereof, Defendants is liable to Plaintiff for judgment that Defendants’  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  62. Plaintiff repeats the allegations above as if set forth here.   63. Alternatively, Defendants’ debt collection efforts attempted and/or directed towards the  Plaintiff violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692f.   64. Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or unconscionable  means in connection with the collection of any debt.   66. By reason thereof, Defendants is liable to Plaintiff for judgment that Defendants’  conduct violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs and  attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.  