12.  Plaintiff is a natural person obligated, or allegedly obligated, to pay a debt  owed or due, or asserted to be owed or due, a creditor other than Defendant.   13.  Plaintiff’s obligation, or alleged obligation, owed or due, or asserted to be  owed or due, a creditor other than Defendant, arises from a transaction in which the  money, property, insurance, or services that are the subject of the transaction were  incurred primarily for personal, family, or household purposes—namely, a personal  credit card (the “Debt”).     15.  On November 10, 2014, Defendant sent Plaintiff an initial written  communication requesting payment of an $18,083.99 balance (the “Letter”).    16.  A true and exact copy of Defendant’s Letter is attached as Exhibit A.     17.  The Letter states, in relevant part:  If you notify this firm within thirty (30) days after your  receipt of this letter, that the debt or any portion thereof, is  disputed, we will obtain verification of the debt or a copy of  the judgment, if any, and mail such verification or judgment  to you.  Upon your written request within the same thirty (30)  day period mentioned above, we will provide you with the  name and address of the original creditor, if different from the  current creditor.    Exhibit A.   18.  Defendant’s Letter failed to disclose that Defendant would only be required  to obtain verification of the debt or a copy of the judgment, if any, and mail a copy of  such verification or judgment to the consumer if the consumer disputed the debt in  writing. Exhibit A; see 15 U.S.C. § 1692g(a)(4).   19.  Defendant did not send a written communication that contained the proper  notice of Plaintiff’s rights under § 1692g(a)(4) within five days of the initial  communication.  20.  Plaintiff repeats and re-alleges all factual allegations above.   22.  Upon information and belief, Defendant has used the same form or  template that was used to create the Letter to send substantially similar or materially  identical letters in an attempt to collect a debt from 50 or more individuals.   23.  Plaintiff brings this class action on behalf of herself and all others similarly  situated.  Specifically, Plaintiff seeks to represent a class of individuals defined as:  All consumers in the State of Arizona to whom  Defendant, in the year prior to the filing of this complaint  and in connection with the collection of any debt, sent an  initial communication that failed to convey to the  consumer that a dispute of the debt, or any portion thereof,  had to be made in writing in order to obtain from  Defendant verification of the alleged debt or a copy of the  judgment against the consumer; and where Defendant did  not send the disclosures required by § 1692g in a  subsequent communication within 5 days of the initial  communication.   24.  The proposed class specifically excludes the United States of America, the  State of Arizona, counsel for the parties, the presiding United States District Court Judge,  the Judges of the United States Court of Appeals for the Ninth Circuit, and the Justices of  the United States Supreme Court, all officers and agents of Defendant, and all persons  related to within the third degree of consanguinity or affection to any of the foregoing  persons.   25.  The class is averred to be so numerous that joinder of members is  impracticable.     27.  The class is ascertainable in that the names and addresses of all class  members can be identified in business records maintained by Defendant.   28.  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) Defendant’s violations of the FDCPA; (c) the  availability of statutory penalties; and (d) attorneys’ fees and costs.     29.  Plaintiff’s claims are typical of those of the class she seeks to represent.     30.  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 each subclass would require proof of the same  material and substantive facts.     31.  Plaintiff possesses the same interests and has suffered the same injuries as  each class member. Plaintiff asserts identical claims and seeks identical relief on behalf  of the unnamed class members.   32.  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.   33.  Plaintiff is willing and prepared to serve this Court and the proposed class.     35.  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.     36.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(1)(A) and  23(b)(1)(B). The prosecution of separate actions by individual members of the class  would, as a practical matter, be dispositive of the interests of other members of the class  who are not parties to the action or could substantially impair or impede their ability to  protect their interests.     37.  The prosecution of separate actions by individual members of the class  would create a risk of inconsistent or varying adjudications with respect to individual  members of the class, which would establish incompatible standards of conduct for the  parties opposing the class. Such incompatible standards of conduct and varying  adjudications, on what would necessarily be the same essential facts, proof and legal  theories, would also create and allow the existence of inconsistent and incompatible  rights within the class.     38.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(2) in that  Defendant has acted or refused to act on grounds generally applicable to the class,  making final declaratory or injunctive relief appropriate.   40.  Moreover, a class action is superior to other methods for the fair and  efficient adjudication of the controversies raised in this Complaint in that: (a) individual  claims by the class members will be impracticable as the costs of pursuit would far  exceed what any one plaintiff or class member has at stake; (b) as a result, very little  litigation has been commenced over the controversies alleged in this Complaint and  individual members are unlikely to have an interest in prosecuting and controlling  separate individual actions; and (c) the concentration of litigation of these claims in one  forum will achieve efficiency and promote judicial economy.   41.  Plaintiff repeats and re-alleges each and every factual allegation above.   42.  The FDCPA requires a debt collector to send a consumer, either in the  initial communication with the consumer or within five days thereafter, a written notice  containing, among other requirements, “a statement that if the consumer notifies the debt  collector in writing within the thirty-day period that the debt, or any portion thereof, is  disputed, the debt collector will obtain verification of the debt or a copy of a judgment  against the consumer and a copy of such verification or judgment will be mailed to the  consumer by the debt collector.”  15 U.S.C. § 1692g(a)(4) (emphasis added).   VIOLATION OF 15 U.S.C. § 1692g(a)(4)  