Plaintiff’s claims are barred, in whole or in part, because the Complaint fails to  state a claim upon which relief may be granted.  SECOND AFFIRMATIVE DEFENSE  Plaintiff’s claims are barred to the extent that any violation of the FDCPA was  unintentional, resulting from a bona fide error notwithstanding the maintenance of  procedures reasonably adapted to avoid such error.  WHEREFORE, the defendant requests that the plaintiff’s Complaint be dismissed  with prejudice and that the court grant defendants such other relief as may be required  by the interests of justice, including without limitation, costs of defense, including a  reasonable attorney fee.  Date: April 16, 2012  