 ALLEGATIONS  13.     On a date or dates unknown to Plaintiff, Plaintiff incurred a financial obligation, namely a consumer credit account issued by Wells Fargo Bank, N.A. (hereinafter “the debt”).  The debt was incurred primarily for personal, family, or household purposes (e.g. purchase of clothing, groceries, gasoline, etc.) and is therefore a “debt” as that term is defined by 15 U.S.C. § 1692a(5).  14.     Plaintiff is informed and believes, and thereon alleges, that sometime after she defaulted on her consumer credit account with Wells Fargo Bank, N.A., the defaulted debt was sold, assigned, or otherwise transferred from Wells Fargo Bank, N.A., to PORTFOLIO, either directly or through a series of intermediate assignees.  Plaintiff is informed and believes, and thereon alleges, that Wells Fargo Bank, N.A., retained no interest in Plaintiff’s defaulted account after the sale, assignment, and transfer of the debt to PORTFOLIO.  15.     Plaintiff is informed and believes, and thereon alleges, that sometime thereafter on a date unknown to her, the debt was consigned, placed, or otherwise assigned to H&H by PORTFOLIO for the purposes of collection from Plaintiff.  16.     On or about November 22, 2010, Defendants filed a lawsuit against Plaintiff in the Superior Court of California, San Mateo County captioned Portfolio Recovery Associates, LLC v. Julia Meza, Case No. CLJ500834 (hereinafter the “state court action”) which sought to collect the defaulted consumer debt from Plaintiff.  17.     Thereafter,  on  or  about  April  11,  2014,  Defendants  sent  a  document  titled Declaration of Plaintiff in Lieu of Personal Testimony at Trial (CCP   §   98) directly to Plaintiff.  A true and accurate copy of the Declaration of Plaintiff in Lieu of Personal Testimony at Trial (CCP   §   98) is attached hereto, marked Exhibit “1,” and by this reference is incorporated herein. - 6 - 31.     Plaintiff brings this action on behalf of a class of all other persons similarly situated, pursuant to Rules 23(a), (b)(2) and (b)(3) of the Federal Rules of Civil Procedure.  32.     Plaintiff tentatively defines the class as (i) all persons residing in California (ii) who were served by Defendants with a Declaration in Lieu of Personal Testimony at Trial, pursuant to California Code of Civil Procedure § 98 (iii) where the declarant was located more than 150 miles from the courthouse where the collection lawsuit was pending (iv) in an attempt to collect a past due account alleged to be due PORTFOLIO (v) regarding a debt incurred for personal, family, or household - 9 -