10.   The Proof of Claim admitted that the last transaction and payment date was June 10,  2002, over eleven years prior to the Plaintiff’s bankruptcy filing, and that the debt was charged off on  January 31, 2003, over ten years prior to the bankruptcy filing.  See Exhibit A, page 3.    12.   Defendant’s Proof of Claim sought payment of a debt that was barred by the  Pennsylvania statute of limitations.   13.   Threatening or attempting litigation to collect a debt barred by the statute of  limitations is a violation of the FDCPA.  See Huertas v. Galaxy Asset Management, 641 F.3d 28 (3d  Cir. 2011).   14.   Defendant’s filing of its Proof of Claim violated the FDCPA in the following manner:  (a)  using false, deceptive or misleading representations or means in connection  with the collection of debt, in violation of section 1692e;  (b)  falsely representing the character, amount or legal status of the debt, in  violation of section 1692e(2);  (c)  using a false representation or deceptive means to collect or attempt to  collect a debt, in violation of section 1692e(10);  (d)  using unfair or unconscionable means to attempt to collect a debt, in  violation of section 1692f, see Crawford v. LVLV Funding, LLC, 2014 WL 3361226 (11th Cir.  2014);  (e)  otherwise using false, deceptive, misleading and unfair or unconscionable  means to collect or attempt to collect an alleged debt from the Plaintiff.   15.   The acts of Defendant as above described have caused Ms. Torres harm.   17.   Plaintiff brings this action individually and as a class action, pursuant to  Rules 23(a) and 23(b) of the Federal Rules of Civil Procedure, on behalf of the following Class:     All consumers in the in the United States of America and its territories as to  whom, during the one year prior to the filing of this action and continuing  through the resolution of this action, Defendant filed a proof of claim in a  bankruptcy case where the breach of the contract had occurred prior to the  expiration of the applicable statute of limitations.    18.   The Class is so numerous that joinder of all members is impracticable.  Although  the precise number of Class members is known only to Defendant, Defendant regularly collects or  attempts to collect debt from consumers through the filing of proofs of claim in bankruptcy cases.     19.   There are questions of law and fact common to the Class which predominate over  any questions affecting only individual Class members.  The principal common questions include  whether the Defendant violated the FDCPA by attempting to obtain payment of a time-barred debt  by filing a proof of claim in a debtor’s bankruptcy case.   20.   Plaintiff’s claims are typical of the claims of the Class, which all arise from the  same operative facts and are based on the same legal theories.   21.   Plaintiff will fairly and adequately protect the interests of the Class.  Plaintiff is  committed to vigorously litigating this matter and has retained counsel experienced in handling  class actions and claims involving unfair collection and unlawful business practices.  Neither  Plaintiff nor her counsel has any interests which might cause them not to vigorously pursue this  claim.   23.   A class action is a superior method for the fair and efficient adjudication of this  controversy.  The interest of Class members in individually controlling the prosecution of  separate claims against Defendant is small because the maximum statutory damages in an  individual action under the FDCPA are $1,000.00.  Management of the Class claims is likely to  present significantly fewer difficulties than those presented in many class claims.  The identities  of the Class members may be obtained from Defendant’s records.     VI.  6.   On October 7, 2013, Plaintiff filed a Chapter 13 bankruptcy in the United States  Bankruptcy Court for the Eastern District of Pennsylvania, case number 13-18786-bif.   7.   On or about November 22, 2013, Defendant filed a Proof of Claim in the aforesaid  bankruptcy case seeking payment for an alleged debt in the amount of $1,296.86 for “money loaned”   by Household/Orchard Bank.  A true and correct copy of the Proof of Claim is attached hereto as  Exhibit A.   8.   The alleged debt at issue arose out of transactions which were primarily for personal,  family or household purposes.   9.   The Proof of Claim was a representation or means used in connection with the attempt  to collect a debt and was an effort to obtain payment by legal proceeding.  