1. The amount of the debt;   11.  Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of:   a. all individuals;  b. to whom Client Services sent an initial collection letter attempting to collect a  consumer debt;  c. that including deceptive accounting of the actual balance owed;  d. 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.   13.  The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf they attempt to collect and/or  have purchased debts.  4   14.  Excluded from the Plaintiff Class are the Defendants and all officer, 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.    15.  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 forms attached  as Exhibits A, violate 15 U.S.C. §§ l692e and 1692g.   16.  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 Classes 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.  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 there is  a well-defined community interest in the litigation:  a. Numerosity: The Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff Class defined above is so numerous that joinder of all members  would be impractical.  b. Common Questions Predominate: Common questions of law and fact exist  as to all members of the Plaintiff Class and those questions predominance over  any questions or issues involving only individual class members. The principal  5  issue is whether the Defendant’s written communications to consumers, in the  forms attached as Exhibit A violate 15 U.S.C. § l692e and §1692g.  c. Typicality: The Plaintiff’s claims are typical of the claims of the class  members. The Plaintiff and all members of the Plaintiff Class have claims  arising out of the Defendant’s common uniform course of conduct complained  of herein.  d. Adequacy: The Plaintiff will fairly and adequately protect the interests of the  class members insofar as Plaintiff has no interests that are adverse to the absent  class members. The Plaintiff is committed to vigorously litigating this matter.  Plaintiff has also retained counsel experienced in handling consumer lawsuits,  complex legal issues, and class actions. Neither the Plaintiff nor her counsel  have any interests which might cause them not to vigorously pursue the instant  class action lawsuit.  e. Superiority: A class action is superior to the other available means for the fair  and efficient adjudication of this controversy because individual joinder of all  members would be impracticable. Class action treatment will permit a large  number of similarly situated persons to prosecute their common claims in a  single forum efficiently and without unnecessary duplication of effort and  expense that individual actions would engender.   18.  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.  6   19.  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).  2. The name of the creditor to whom the debt is owed;   20.  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.   21.  Some time prior to February 16, 2018, an obligation was allegedly incurred to  Chase Bank.   22.  The Chase Bank obligation arose out of transactions in which the funds obtained  from the creditor were used primarily for personal, family or household purposes.   23.  The alleged Chase Bank obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).   24.  Chase Bank is a "creditor" as defined by 15 U.S.C.§ 1692a(4).   25.  Chase Bank or a subsequent owner of the Chase Bank debt contracted with the  Defendant to collect the alleged debt.   26.  Defendant 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 – February 16, 2018 Collection Letter   27.  On or about February 16, 2018, Defendant sent the Plaintiff an initial contact notice  (the “Letter”) regarding the alleged debt owed to Chase Bank. See Exhibit A.  7   28.  When a debt collector solicits payment from a consumer, it must, within five days  of an initial communication send the consumer a written notice containing:  (1) the amount of the debt;  (2) the name of the creditor to whom the debt is owed;  (3) a statement that unless the consumer, within thirty days after receipt of the notice,  disputes the validity of the debt, or any portion thereof, the debt will be assumed to be  valid by the debt collector;  (4) a statement that if 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 the judgment against the consumer and a copy of  such verification or judgment will be mailed to the consumer by the debt collector; and  (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. 15 U.S.C. § 1692g(a).   29.  The required disclosures set forth in 15 U.S.C. §1692g(a) are more commonly  known as the “G Notice”.   3. A statement that unless the consumer, within thirty days after receipt of  the notice, disputes the validity of the debt, or any portion thereof, the  debt will be assumed to be valid by the debt-collector;   30.  The FDCPA further provides that ''if 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 shall cease collection . . . until the debt collector obtains  verification of the debt . . . and a copy of such verification is mailed to the consumer by the  debt collector.'' 15 U.S.C. § 1692g(b).   31.  Although a collection letter may track the statutory language, ''the collector  nevertheless violates the Act if it conveys that information in a confusing or contradictory  8  fashion so as to cloud the required message with uncertainty.'' Russell v. EQUIFAX A.R.S.,  74 F.3d 30, 35 (2d Cir. 1996) (''It is not enough for a debt collection agency to simply include  the proper debt validation notice in a mailing to a consumer-- Congress intended that such  notice be clearly conveyed.''). Put differently, a notice containing ''language that  'overshadows or contradicts' other language informing a consumer of her rights . . . violates  the Act.'' Russell, 74 F.3d at 34.   32.  The top of the letter states:  Balance due at Charge Off:  $1,915.77  Interest Post Charge Off:  $0.00  Other Charges Post Charge Off:  $0.00  Payments Made Post Charge Off:  $0.00  Balance Due:   $1,878.77   33.  Defendant deceptively lists multiple balances due without an account for the change  in amounts.   34.  Defendant should be aware of a payment being made and properly accounted for.   35.  Plaintiff incurred an informational injury as Defendant falsely stated the amounts  owed.   36.  Defendant’s false statement overshadowed Plaintiff’s §1692g right to dispute or  validate the debt as he was uninformed as to what amount he actually owed.   37.  As a result of Defendant's deceptive, misleading and unfair debt collection  practices, Plaintiff has been damaged.  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.  9   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. § 1692e.   4. A statement that the consumer notifies the debt collector in writing  within 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. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   41.  Defendant violated §1692e :   a. As the Letter it is open to more than one reasonable interpretation, at least one  of which is inaccurate.  b. By making a false and misleading representation in violation of §1692e(10).   42.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages,  costs and attorneys’ fees.  43.  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.   44.  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.   45.   Pursuant to 15 USC §1692g, a debt collector:  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 –  10   46.  The Defendant violated 15 U.S.C. §1692g, by not clearly stating the amount owed  and deceived the consumer not to exert its rights under the FDCPA.   47.   By reason thereof, Defendant is liable to Plaintiff for judgment 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.  §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  