1. The amount of the debt;   10.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   11.  The Class consists of:   a. all individual consumers in the State of New Jersey;  b. to whom Defendant sent an in initial collection letter attempting to collect a  consumer debt;  c. in which Defendant states “see list below” next to “creditor”;  d. without providing a clearly identifiable list with the original creditor’s name;   e. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (2l) days after the filing of this action.   12.  The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.   14.  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 Defendant’s written communications to consumers, in the form attached as  Exhibit A violates 15 U.S.C. § l692e et seq.   15.  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.   17.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.   19.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   2. The name of the creditor to whom the debt is owed;   20.  Some time prior to March 4, 2021, upon information and belief, an obligation was  incurred by Plaintiff for alleged medical treatments received by Plaintiff’s minor son. The  subject debt was allegedly incurred by Plaintiff’s son solely for personal, household or family  purposes.   21.  Upon information and belief, a creditor contracted with Defendant to act as its agent  in collecting the subject debt from the Plaintiff.    22.  The Plaintiff is a “consumer” as defined by 15 U.S.C.§ 1692a(3).   23.  The subject obligation is consumer-related, and therefore a "debt" as defined by 15  U.S.C.§ 1692a(5).   24.  Defendant was contracted by a creditor for the purpose of debt collection. Therefore,  Defendant is a “debt collector” as defined by 15 U.S.C.§ 1692a(6).  Violation – March 4, 2021 Collection Letter   25.  On or about March 4, 2021, the Defendant sent the Plaintiff an initial collection letter  (“Letter”) regarding the alleged debt. (See Letter at Exhibit A.)   26.  Toward the top portion, the Letter states:  “Creditor; See List Below”   28.  In addition, toward the bottom of the Letter, Defendant includes a caption with the  following text, in relevant part:  33.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   34.  Defendant’s 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.   35.  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.   37.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant’s  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  38.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   39.  Defendant’s 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. § 1692g.   4. A statement that the consumer notifies the debt collector in  writing within the thirty-day period that the debt, or any portion  thereof, is disputed, the debt collector will obtain verification of  the debt or a copy of a judgment against the consumer and a copy  of such verification or judgment will be mailed to the consumer  by the debt collector; and   40.  Pursuant to 15 U.S.C. § 1692g:  Within five days after the initial communication with a consumer in  connection with the collection of any debt, a debt collector shall, unless the  following information is contained in the initial communication or the  consumer has paid the debt, send the consumer a written notice containing –   41.  Defendant violated this section by failing to meaningfully identify the name of the  creditor, as required by §1692g(2) in an initial collection letter.   42.  By reason thereof, Defendant is liable to Plaintiff for judgment in that Defendant's  conduct violated Section 1692g et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  5. A statement that, upon the consumer’s written request within the  thirty-day period, the debt collector will provide the consumer  with the name and address of the original creditor, if different  from the current creditor.   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. §1692g et seq.  