11.  Plaintiff brings this action as a state wide class action, pursuant to Rule 23 of the  Federal Rules of Civil Procedure (hereinafter “FRCP”), on behalf of himself and all New Jersey  consumers and their successors in interest (the “Class”), who have received debt collection  letters and/or notices from the Defendants which are in violation of the FDCPA, as described in  this Complaint.   12.  This Action is properly maintained as a class action. The Class consists of:   All New Jersey consumers who were sent letters and/or notices from  SOKOLOFF, which contained at least on one of the alleged violations of 15  U.S.C. § 1692 et seq. as set forth herein.   The Class period begins one year to the filing of this Action.   13.  The Class satisfies all the requirements of Rule 23 of the FRCP for maintaining a  class action:   Upon information and belief, the Class is so numerous that joinder of all  members is impracticable because there are hundreds and/or thousands of  persons who were sent debt collection letters and/or notices from the  Defendants that violate specific provisions of the FDCPA. Plaintiff is  complaining of a standard form letter, notice and/or practice. (See Exhibit A,  except that the undersigned attorney has, in accordance with Fed. R. Civ. P.   14.  Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).   15.  At some time prior to December 25, 2014, Plaintiff allegedly incurred a financial  obligation to PRINCETON RADIOLOGY ASSOCIATES ("PRINCETON RADIOLOGY").   16.  The PRINCETON RADIOLOGY obligation arose out of a transaction, in which  money, property, insurance or services, which are the subject of the transaction, are primarily for  personal, family or household purposes.   17.  The PRINCETON RADIOLOGY obligation is a "debt" as defined by 15 U.S.C. §  1692a(5).   19.  At some time prior to December 25, 2014, the PRINCETON RADIOLOGY  obligation was placed with SOKOLOFF for the purpose of collection.    20.  At the time the PRINCETON RADIOLOGY obligation was placed with  SOKOLOFF for the purpose of collection, the balance was past due.   21.  At the time the PRINCETON RADIOLOGY obligation was placed with  SOKOLOFF for the purpose of collection, the obligation was in default.   22.  SOKOLOFF caused to be delivered to Plaintiff a letter dated December 25, 2014,  which was addressed to Plaintiff.  Exhibit A.   23.  The December 25, 2014 letter was sent to Plaintiff in connection with the  collection of the PRINCETON RADIOLOGY obligation.    24.  The December 25, 2014 letter is a “communication” as defined by 15 U.S.C. §  1692a(2).   25.  Upon receipt, Plaintiff read the December 25, 2014 letter.   26.  The December 25, 2014 letter states in part:  39.  Plaintiff, on behalf of himself and others similarly situated, repeats and realleges  all prior allegations as if set forth at length herein.   40.  Collection letters and/or notices, such as those sent by Defendant, are to be  evaluated by the objective standard of the hypothetical “least sophisticated consumer.”   41.  Defendant violated 15 U.S.C. § 1692e of the FDCPA by using any false,  deceptive or misleading representation or means in connection with his attempts to collect debts  from Plaintiff and others similarly situated.   43.  Section 1692e(3) of the FDCPA prohibits a debt collector from falsely  representing or implying that any communication is from an attorney.    44.  Defendant violated 15 U.S.C. § 1692e(3) of the FDCPA by falsely representing  meaningful attorney involvement in his collection letters to Plaintiff and others similarly  situated.   45.  Defendant violated 15 U.S.C. § 1692 et seq., § 1692e and § 1692e(3) of the  FDCPA by causing Plaintiff and others similarly situated to be confused as to whether Defendant  was meaningfully involved in the collection attempts as an attorney.   46.  Defendant violated 15 U.S.C. § 1692 et seq., § 1692e and § 1692e(3) of the  FDCPA by causing Plaintiff and others similarly situated to be confused as to whether Defendant  was acting as an attorney in his collection attempts and whether Defendant’s collection letters  implied potential legal action.   47.  Defendant violated 15 U.S.C. § 1692e and § 1692e(3) of the FDCPA by making a  false, deceptive, or misleading representation in his collection letters to Plaintiff and others  similarly situated regarding his level of meaningful attorney involvement.   48.  Section 1692e(5) of the FDCPA prohibits a debt collector from threatening to take  any action that cannot legally be taken.   49.  Defendant’s December 25, 2014 letter violated 15 U.S.C. §1692e(5) by falsely  implying that a lawsuit could be instituted by Defendant.   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS   “IF YOU HAVE NOT ALREADY MADE AN ARRANGMENT  WITH MY OFFICE, PLEASE REMIT THE BALANCE DUE  DIRECTLY TO THIS OFFICE SO I MAY CLOSE OUT THIS 