10.  On April 13, 2018, the Bankruptcy Noticing Center provided Official Form 309A— Notice of Chapter 7 Bankruptcy Case to Northwoods Bank via first class mail to the  scheduled address. It was not returned as undeliverable.    11.  On July 24, 2018, the Honorable Robert J. Kressel entered an order of discharge,  effectively discharging Plaintiffs of their debt to Defendant and various other creditors.    12.  On July 27, 2018, the Bankruptcy Noticing Center provided to Northwoods Bank via  first class mail. It was not returned as undeliverable.    13.  Thereafter, Plaintiffs worked to repair their credit from the damage caused by the  bankruptcy.    14.  On September 16, 2019, Plaintiff Brian Stuckey filed a lawsuit against Northwoods  Bank. See Stuckey v. Northwoods Bank, USDC 19-cv-2525 JNE//LIB, for alleged  violations of the Fair Credit Reporting Act.   15.  Sometime thereafter September 2019, Northwoods Bank hired Defendant Gislason  to defend it against Plaintiffs in the Stuckey v. Northwoods Bank action.   17.  Defendant Gislason’s February 11, 2020, Preforeclosure Notice communication  states, in pertinent part:  25.  The Class shall be subject to the following exclusions, the above criterion  notwithstanding: (1) counsel for Plaintiffs and the Class; (2) counsel for Defendant  Gislason; (3) the assigned Judge, Magistrate Judge, and their clerks and staff.    26.  This action may properly be maintained as a class action as it satisfies the numerosity,  commonality, typicality, adequacy, predominance, and superiority requirements of  Rule 23(a)-(b) of the Federal Rules of Civil Procedure for certification.   Numerosity   27.  The attached Exhibit 1 is a form letter and notice and therefore Defendant Gislason  regularly and routinely discloses consumer’s debts to third-parties not permitted by  law.    28.  It is plausible that Defendant Gislason subjected a large number of consumers to the  same or substantially similar conduct.    29.  Therefore, it is plausible that joinder of all these customers into a single lawsuit would  be impracticable.    30.  The exact number of class members is unknown at this time but, upon information and  belief, exceeds 40.    32.  All members of the Class have had their rights violated by Defendant Gislason in the  same manners.    33.  Common questions of law and fact exist as to the Class such as:  a)  Whether Defendant Gislason regularly and routinely sends out letters similar  to Exhibit 1;  b)  Whether Defendant Gislason notifies foreclosure prevention counseling  agencies of consumers’ debts and obligations;   c)  Whether or not such conduct constitutes a violation of 15 U.S.C. § 1692c(b);  d)  Whether or not Defendant Gislason’s conduct was willful or committed with  reckless disregard and negligent; and  e)  Whether Defendant Gislason sends letters to consumers similar to Exhibit 1  and does so in an attempt to collect upon debts.   35.  These common questions of law and fact predominate over any questions affecting  individual class members and the answers to these common questions of law and fact  will advance the adjudication of the litigation as to all class members.   Typicality   36.  Plaintiffs’ claims are typical of the claims brought by the Class.    37.  Plaintiffs’ claims and the claims brought by the Class arise from Defendant’s same  conduct.    38.  Accordingly, if brought and adjudicated individually, the claims would require proof  of the same substantive facts.    39.  Any defenses that Defendant Gislason may have regarding liability or quantum of  damages with respect to Plaintiffs’ claims would generally be applicable to the  members of the Class.   Adequacy   40.  Plaintiffs bring this lawsuit with the intention of stopping Defendant Gislason’s  unlawful practices and to recover for all of its customers affected.    41.  Plaintiffs will fairly and adequately protect the interests of all members of the Class.   43.  Plaintiffs and their counsel will continue to vigorously advocate on behalf of the  members of the Class.   44.  Neither Plaintiffs nor their counsel have an interest adverse to or in conflict with the  interests of the members of the Class.   45.  Plaintiffs and their counsel are committed to expending the time, energy, and resources  necessary to successfully adjudicate this action on behalf of the Class.   Risk of Inconsistent or Dispositive Adjudications   46.  Certification is appropriate pursuant to Rule 23(b)(1)(B) of the Federal Rules of Civil  Procedure because the prosecution of separate actions by individual class members  would, as a practical matter, be dispositive of the interests of all class members or  could substantially impair or impeded their ability to protect their interests.    47.  Certification is appropriate pursuant to Rule 23(b)(2) of the Federal Rules of Civil  Procedure because Defendant Gislason has acted or refused to act on grounds  generally applicable to the members of the Class.   Superiority   48.  Certification is appropriate pursuant to Rule 23(b)(3) of the Federal Rules of Civil  Procedure as a class action is superior to all other available methods to fairly and  efficiently adjudicate this action.    50.  Thus, the members of the Class have little interest in prosecuting any litigation given  the small amounts at stake relative to the cost, risk, delay, and uncertainly of  recovery.   51.  Concentrated litigation would permit similarly situated persons to prosecute their  common claims efficiently, without unnecessary duplication of effort and expense  and would, therefore, promote judicial economy.    52.  The members of the Class had their rights violated by Defendant Gislason in the  same manner.    53.  Upon information and belief, few members of the Class are aware that Defendant  Gislason’s actions and inactions were wrongful.     54.  The class notice mechanism provides an opportunity for members of the Class to  learn of their rights and seek redress.   57.  On or about February 11, 2020, Defendant Gislason caused to be mailed to Plaintiffs  via certified mail a letter of Notice of Default of Note and Mortgage, which included  a Preforeclosure Notice.   58.  In the February 11, 2020, communication Defendant Gislason stated that it had  communicated Plaintiffs’ alleged debt with a third-party in violation of 15 U.S.C. §  1692c(b).   59.  By sending Exhibit 1 directly to Plaintiff Brian Stuckey, whom it knew was  represented by counsel, was in violation of 15 U.S.C. § 1692c(a)(2).   6.  On December 12, 2014, Plaintiffs secured a $63,063.00 home mortgage loan, loan  number 44XXX, from Northwoods Bank of Minnesota (“Northwoods Bank”).    60.  Defendant Gislason’s violations of 15 U.S.C. § 1692c(b) and § 1692c(a) renders  Defendant Gislason liable for Plaintiffs’ actual damages, statutory damages, as well  as the costs and attorney’s fees incurred in bringing this action, pursuant to 15  U.S.C.  1692k.  8.  On April 10, 2018, Plaintiffs filed their Voluntary Chapter 7 Petition in the United  States Bankruptcy Court District of Minnesota. See, Case No. 18-50246-RJK.    9.  In their petition, Plaintiffs listed Northwoods Bank as a creditor with a secured claim  against them relating to loan number 44XXX, totaling $53,349.00.    VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT –  15 U.S.C. § 1692, et seq.  