15.  At all times relevant, the principal purpose of MCS was the collection of debts  using the mails and telephone.    16.  At all times relevant, MCS regularly attempted to collect debts alleged to be due  to another.    17.  At all times relevant, MCS regularly collected or attempted to collect debts due or  alleged to be due another.   18.  At all times relevant, MCS regularly collected or attempted to collect debts owed  or due or asserted to be owed or due another, which debts were incurred primarily for personal,  family or household purposes.   19.  At all times relevant, MCS used the mail, telephone or other instruments of  interstate commerce in its attempts to collect debts due or alleged to be due another.   21.  At all times relevant, the principal business engaged in by MCS was the collection  of debts, which debts were incurred primarily for personal, family or household purposes.   22.  MCS is a “debt collector” within the scope of the definition contained in 15  U.S.C. § 1692a(6) and interpretations thereof.   23.  Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3) of the FDCPA.   24.  Plaintiff and others similarly situated are consumers as they are natural persons  allegedly obligated to pay a debt, in, which the money, property, insurance, or services, which  was the subject of the transaction, was primarily for personal, family and/or household purposes.   25.  On or about February 10, 2015, Plaintiff incurred a financial obligation to  39.  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 York  consumers and their successors in interest (the “Class”), who were sent debt collection letters  and/or notices from the Defendants which are in violation of the FDCPA, as described in this  Complaint.   40.  This Action is properly maintained as a class action.  The Class is initially defined  as follows:  All New York consumers who were sent letters and/or  notices from MCS, concerning a debt owed to  MAIMONIDES MEDICAL CENTER which contained at  least one of the alleged violations of 15 U.S.C. § 1692 et  seq. herein.  The Class period begins one year to the filing  of this Action.  The class may be subsequently refined. Specifically excluded from this class is any Judge  presiding over this Action and members of their immediate families.   41.  Plaintiff seeks to recover statutory damages, attorney’s fees and costs on behalf of  all class members under the Fair Debt Collection Practices Act.    43.  There are questions of law and fact common to the members of the Class that  predominate over questions affecting only individuals.  These common questions include, but are  not limited to:  a.  Whether Defendant violated various provisions of the FDCPA;  b.  Whether Plaintiff and the Class have been injured by Defendants’ conduct;  c.  Whether Plaintiff and the Class have sustained damages and are entitled to  restitution as a result of Defendants’ wrongdoing and if so, what is the   proper measure and appropriate statutory formula to be applied in    determining such damages and restitution; and  d.  Whether Plaintiff and the Class are entitled to declaratory and/or injunctive   relief.   44.  A class action is superior to other available methods for the fair and efficient  adjudication of this controversy since joinder of all members is impracticable.  While the  economic damages suffered by the individual class members are significant, the amount may be  modest compared to the expense and burden of individual litigation. Additionally, the FDCPA  statutory scheme provides for statutory damages payable to each class member. A class action  will cause an orderly and expeditious administration of the claims of the Class and will foster  economies of time, effort and expense.   45.  The claims of the Plaintiff are typical of the claims of the members of the Class.    46.  The questions of law and/or fact common to the members of the Class  predominate over any questions affecting only individual members.    47.  Plaintiff does not have interests antagonistic to those of the Class.   49.  Plaintiff will fairly and adequately protect the interests of the Class, and has  retained competent counsel experienced in the prosecution of consumer litigation. Proposed  Class Counsel has investigated and identified potential claims in the action; has a great deal of  experience in handling class actions, other complex litigation, and claims of the type asserted in  this action.   50.  The prosecution of separate actions by individual members of the Class would run  the risk of inconsistent or varying adjudications, which would establish incompatible standards  of conduct for MCS in this action or the prosecution of separate actions by individual members  of the class would create the risk that adjudications with respect to individual members of the  class would as a practical matter be dispositive of the interests of the other members not parties  to the adjudications or substantially impair or impede their ability to protect their interests.   Prosecution as a class action will eliminate the possibility of repetitious litigation.   51.  MCS has acted or refuse to act on grounds generally applicable to the class,  thereby making appropriate final injunctive relief or corresponding declaratory relief with  respect to the class as a whole.   52.  Plaintiff does not anticipate any difficulty in the management of this litigation.  54.  Plaintiff, on behalf of herself and others similarly situated, repeats and realleges all  prior allegations as if set forth at length herein.   55.  MCS violated 15 U.S.C. § 1692 et seq. of the FDCPA in connection with its  communications to Plaintiff and others similarly situated.   56.  MCS violated 15 U.S.C. § 1692g of the FDCPA by using a false, deceptive or  misleading representation or means in connection with its attempts to collect the alleged debts  from Plaintiff and others similarly situated.   57.  Section 1692g of the FDCPA requires the debt collector to give what is  commonly referred to as a thirty-day (30) notice within five (5) days of its communication with  the consumer.   59.  The September 11, 2015 stated in the second paragraph:  60.  The information request section at the bottom of the letters states:  MCS CLAIM SERVICES  DEBTOR #: xxxxxxxxxx  REFERRAL DATE: 09-02-15  99851  71.  Plaintiff repeats the allegations contained in paragraphs 1 through 70 as if the  same were here set forth at length.    72.  Section 1692e(10) of the FDCPA prohibits the use of any false representation or  deceptive means to collect or attempt to collect any debt.   73.  MCS violated Section 1692e(10) of the FDCPA providing language that  misrepresents to the least sophisticated consumer what she must do effectively dispute the  alleged debt.   74.  The September 11, 2015 letter misleads the least sophisticated consumer that she  can only dispute by completing a form and provided personal information such as her social  security number, home telephone number and date of birth.   75.  Upon reading paragraph two of the September 11, 2015 letter from MCS, the least  sophisticated consumer would believe that she did not owe the alleged because she had already  paid it, that in order to effectively the debt, she would be require to provide the information  requested by MCS at the bottom of the letter, when in fact all she has to so is simply call MCS  and state that she dispute the alleged debt.   76.  Plaintiff and the class members have been accorded a procedural right to protect  their concrete interest in receiving certain information relating to their right to dispute an alleged  debt and to invoke the consumer protections provided for by such dispute.   78.  The deprivation of certain information relating to the consumers' right to dispute  and alleged debt creates a cognizable injury-in-fact to Plaintiff and the class members.   79.  Plaintiff suffered an informational injury due to MCS' violation of 15 U.S.C. §  1692e(10) of the FDCPA in connection with its communications of September 11, 2015 to  Plaintiff.   80.  Plaintiff suffered a risk of economic injury due to MCS' violation of 15 U.S.C. §  1692e(10) of the FDCPA in connection with its communications of September 11, 2015 to  Plaintiff.   FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. § 1692  VIOLATION OF 15 U.S.C. § 1692g(a)(3)   FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. § 1692  VIOLATION OF 15 U.S.C. § 1692e(10)  