25.  Defendant alleges Plaintiff owes a debt (“the alleged Debt”).     26.  The alleged Debt is an alleged obligation of Plaintiff to pay money arising out of  a transaction in which the money, property, insurance, or services which are the subject of the  transaction are primarily for personal, family, or household purposes.   27.  The alleged Debt does not arise from any business enterprise of Plaintiff.   28.  The alleged Debt is a “debt” as defined by 15 U.S.C. § 1692a(5).   29.  At an exact time known only to Defendant, the alleged Debt was assigned or  otherwise transferred to Defendant for collection.    30.  At the time the alleged Debt was assigned or otherwise transferred to Defendant  for collection, the alleged Debt was in default.   31.  In its efforts to collect the alleged Debt, Defendant contacted Plaintiff by letter  (“the Letter”) dated June 8, 2018. (A true and accurate copy is annexed hereto as “Exhibit 1.”)   32.  The Letter conveyed information regarding the alleged Debt.   33.  The Letter is a “communication” as defined by 15 U.S.C. § 1692a(2).    34.  The Letter was the initial written communication Plaintiff received from  Defendant concerning the alleged Debt.  35.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     36.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   37.  As relevant here, 15 U.S.C. § 1692g(a)(1) requires the written notice provide “the  amount of the debt.”   39.  To comply with 15 U.S.C. § 1692g(a)(1), a statement of “the amount of the debt”  must accurately convey, from the perspective of the least sophisticated consumer, the actual  amount of the debt.   40.  The Letter claims that Plaintiff owes $4,071.00.   41.  Plaintiff did not owe $4,071.00 at the time the alleged Debt was assigned or  otherwise transferred to Defendant for collection.   42.  Plaintiff did not owe $4,071.00 at the time Defendant sent Plaintiff the Letter.     43.  Plaintiff did not owe $4,071.00 at the time Plaintiff received the Letter.     44.  As such, Defendant did not clearly convey, from the perspective of the least  sophisticated consumer, the actual amount of the alleged Debt as required by 15 U.S.C. §  1692g(a)(1).    45.  As such, Defendant did not accurately convey, from the perspective of the least  sophisticated consumer, the actual amount of the alleged Debt as required by 15 U.S.C. §  1692g(a)(1).    46.  For the foregoing reasons, Defendant violated 15 U.S.C. § 1692g(a)(1) and is  liable to Plaintiff therefor.  47.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   48.  15 U.S.C. § 1692e provides, generally, that a debt collector may not use any false,  deceptive, or misleading representation or means in connection with the collection of any debt.    49.  15 U.S.C. § 1692e(2)(A) prohibits the false representation of the character,  amount, or legal status of any debt.   50.  15 U.S.C. § 1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.     51.  The Letter claims that Plaintiff owes $4,071.00.   52.  Plaintiff did not owe $4,071.00 at the time the alleged Debt was assigned or  otherwise transferred to Defendant for collection.   53.  Plaintiff did not owe $4,071.00 at the time Defendant sent Plaintiff the Letter.     55.  Defendant's allegation that Plaintiff owed $4,071.00 is a false representation made  in connection with the collection of the alleged Debt in violation of 15 U.S.C. § 1692e.   56.  Defendant's allegation that Plaintiff owed $4,071.00 is a deceptive representation  made in connection with the collection of the alleged Debt in violation of 15 U.S.C. § 1692e.   57.  Defendant's allegation that Plaintiff owed $4,071.00 is a false representation of  the character of the alleged Debt in violation of 15 U.S.C. § 1692e(2)(A).   58.  Defendant's allegation that Plaintiff owed $4,071.00 is the false representation of  the amount of the alleged Debt in violation of 15 U.S.C. § 1692e(2)(A).   59.  Defendant's allegation that Plaintiff owed $4,071.00 is the false representation of  the legal status of the alleged Debt in violation of 15 U.S.C. § 1692e(2)(A).   60.  Defendant's allegation that Plaintiff owed $4,071.00 is a false representation made  in an attempt to collect the alleged Debt in violation of 15 U.S.C. § 1692e(10).   61.  Defendant's allegation that Plaintiff owed $4,071.00 is a deceptive means in an  attempt to collect the alleged Debt in violation of  15 U.S.C. § 1692e(10).   62.  For the foregoing reasons, Defendant violated 15 U.S.C. §§ 1692e, 1692e(2)(A)  and 1692e(10) and is liable to Plaintiff therefor.  63.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     64.  15 U.S.C. § 1692g provides that within five days after the initial communication  with a consumer in connection with the collection of any debt, a debt collector shall, unless the  information is contained in the initial communication or the consumer has paid the debt, send the  consumer a written notice containing certain enumerated information.   65.  As relevant here, 15 U.S.C. § 1692g(a)(2) requires the written notice provide “the  name of the creditor to whom the debt is owed.”   66.  The Letter claims the name of the creditor to whom the alleged Debt is owed is  75.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.   76.  The Letter claims that Plaintiff owes an alleged Debt to JHPDE FINANCE I,  98.  Plaintiff repeats and realleges the foregoing paragraphs as if fully restated herein.     Violations of 15 U.S.C. §§ 1692e, 1692e(2)(A) and 1692e(10)   Violation of 15 U.S.C. § 1692g(b)   Violation of 15 U.S.C. § 1692g(a)(2)   Violation of 15 U.S.C. § 1692g(a)(1)   Violations of 15 U.S.C. §§ 1692e, 1692e(2)(A) and 1692e(10)  