14.  Plaintiff is a natural person allegedly obligated to pay a debt.   16.  Defendant uses instrumentalities of interstate commerce or the mails in a  business the principal purpose of which is the collection of any debts.   17.  Defendant regularly collects or attempts to collect, directly or indirectly,  debts owed or due, or asserted to be owed or due, another.   18.  In connection with the collection of the Debt, Defendant sent Plaintiff  written communication dated May 30, 2019.   19.  A true and correct copy of Defendant’s May 30, 2019 letter (“the Letter”) is  attached hereto as Exhibit A.   20.  The Letter was Defendant’s initial communication with Plaintiff with  respect to the Debt.   21.  Plaintiff received and read the Letter.   22.  The Letter purported to contain the notices required in an initial  communication by 15 U.S.C. § 1692g(a).   23.  The Letter states: “Original Creditor: N AZ RADIOLOGY.” Exhibit A.   24.  The Letter further states that Defendant “will provide you with the name  and address of the original creditor, if different from the current creditor.”  Id.   25.  The Letter does not identify the “current creditor.”   27.  The least sophisticated consumer may reasonably conclude that “N AZ  RADIOLOGY” is the original creditor and that another entity is the creditor to whom the  Debt is owed.   28.  The Letter does not explain who assigned the Debt to Defendant for  collection, nor does it state Defendant’s relationship to “N AZ RADIOLOGY.”   29.  Defendant sent no other written communication to Plaintiff within five days  of sending the Letter.  30.  Plaintiff repeats and re-alleges all factual allegations above.   31.  The Letter is based on a form or template that Defendant uses to send  collection letters to consumers (“Template”).   32.  Defendant has used the Template to send collection letters to over 40  individuals within the year prior to the filing of the original complaint in this matter.     33.  Plaintiff brings this action on behalf of herself and all others similarly  situated.  Specifically, Plaintiff seeks to represent the following class of individuals:  All individuals in the United States to whom Defendant, within the one  year prior to the filing of the original complaint in this action, mailed a  letter based on the Template and where such letter was Defendant’s initial  written communication with the individual with respect to the debt.    35.  The class is averred to be so numerous that joinder of members is  impracticable.     36.  The exact number of class members is unknown to Plaintiff at this time and  can be ascertained only through appropriate discovery.     37.  The class is ascertainable in that the names and addresses of all class  members can be identified in business records maintained by Defendant.    38.  There exists a well-defined community of interest in the questions of law  and fact involved that affect the parties to be represented. These common questions of  law and fact predominate over questions that may affect individual class members. Such  issues include, but are not limited to: (a) the existence of Defendant’s identical conduct  particular to the matters at issue; (b) whether letters based on the Template violate the  FDCPA; (c) the availability of statutory penalties; and (d) attorneys’ fees and costs.     39.  Plaintiff’s claims are typical of those of the class she seeks to represent.     40.  The claims of Plaintiff and of the class originate from the same conduct,  practice, and procedure on the part of Defendant. Thus, if brought and prosecuted  individually, the claims of the members of the class would require proof of the same  material and substantive facts.   42.  Plaintiff will fairly and adequately protect the interests of the class and has  no interests adverse to or which directly and irrevocably conflict with the interests of  other members of the class.   43.  Plaintiff is willing and prepared to serve this Court and the proposed class.     44.  The interests of Plaintiff are co-extensive with and not antagonistic to those  of the absent class members.     45.  Plaintiff has retained the services of counsel who are experienced in  consumer protection claims, as well as complex class action litigation, will adequately  prosecute this action, and will assert, protect and otherwise represent Plaintiff and all  absent class members.     46.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(3) in that the  questions of law and fact that are common to members of the class predominate over any  questions affecting only individual members.   48.  Plaintiff repeats and re-alleges each factual allegation above.   49.  Defendant violated 15 U.S.C. § 1692g(a)(2) by failing to disclose to  Plaintiff the name of the creditor to whom the Debt was owed.    51.  Plaintiff repeats and re-alleges each factual allegation above.   52.  The FDCPA prohibits the use of false, deceptive, or misleading  representations in the collection of debts.  See 15 U.S.C. § 1692e.     53.  “Courts have routinely found debt collection letters to be deceptive where  the letter fails to clearly identify the current creditor of the debt.” Valentin v. Grant  Mercantile Agency, Inc., No. 117CV01019AWISKO, 2017 WL 6604410, at *6 (E.D.  Cal. Dec. 27, 2017).   VIOLATION OF 15 U.S.C. § 1692g(a)(2)   VIOLATION OF 15 U.S.C. § 1692e  