1. Certify this action as a class action.   2. Appoint Alex Cooper as Class Representative of the Class and her attorneys as Class   Counsel.   3. A finding that the Defendant violated the FDCPA and/or an admission from the Defendant   that it violated the FDCPA.     34. Plaintiff adopts and realleges ¶¶ 1-33.   35. Section 1692g of the FDCPA requires that, within 5 days of Defendant’s first  communication to a consumer, Defendant was required to provide Mr. Cooper with an  effective validation notice, containing, among other disclosures, “(2) the name of the  creditor to whom the debt is owed.” See 15 U.S.C. § 1692g(a)(2).   36. Defendant’s form collection letter violates § 1692g(a)(2) of the FDCPA because it failed  to identify effectively the current creditor to whom the debt was owed. See Janetos, 825  F.3rd at 324-325; see also, Long v. Fenton & McGarvey, 2016 U.S. Dist. LEXIS 170421  (S.D. Ind. 2016); Pardo v. Allied Interstate, 2015 U.S. Dist. Lexis 125526 (S.D. Ind.  2015); Deschaine v. National Enterprise Systems, 2013 U.S. Dist. LEXIS 31349 (N.D.  Ill. 2013); Walls v. United Collection Bureau, 2012 U.S. Dist. LEXIS 68079 (N.D. Ill.  2012); Braatz v. Leading Edge Recovery Solutions, 2011 U.S. Dist. LEXIS 123118 (N.D.  Ill. 2011).   37. Defendant’s violation of § 1692g of the FDCPA renders it liable for statutory damages,  costs, and reasonable attorneys’ fees, see, 15 U.S.C. § 1692k.   38. Plaintiff adopts and realleges ¶¶ 1-37.   39. Section 1692e of the FDCPA prohibits a debt collector from using any false, deceptive or  misleading representation or means in connection with the collection of any debt, see, 15  U.S.C. § 1692e.   4. Enter judgment in favor of Plaintiff and the Class, and against Defendant.   40. Making a false statement as to the name of the original creditor is a materially misleading  statement which violates of § 1692e of the FDCPA.  See Tourgeman, supra, 755 F.3d at  1122. By failing to properly identify the correct creditor, Defendant’s letter violated §  1692e of the FDCPA.   41. Defendant’s violation of § 1692e of the FDCPA renders it liable for statutory damages,  costs, and reasonable attorneys’ fees, see, 15 U.S.C. § 1692k.   42. Plaintiff adopts and realleges ¶¶ 1-41.    5   43. Section 1692f of the FDCPA prohibits a debt collector from using any unfair or  unconscionable means to collect or attempt to collect a debt, see, 15 U.S.C. § 1692f.   44. Defendant, by failing to properly identify the creditor violated § 1692f of the FDCPA.   45. Defendant’s violation of § 1692f of the FDCPA renders it liable for statutory damages,  costs, and reasonable attorneys’ fees, see, 15 U.S.C. § 1692k.  46. Plaintiff, Alex Cooper, brings this action individually and as a class action on behalf of  all persons similarly situated in the State of Indiana from whom Defendant attempted to  collect a delinquent consumer debt via the same form collection letter that Defendant sent  to Plaintiff which failed to explain who owns the alleged debt at issue in this matter.  This  action seeks a finding that Defendant’s form letter violated the FDCPA and asks the  Court award damages as authorized by §1692k(a)(2) of the FDCPA.   47. Defendant regularly engages in debt collection, using the same form collection letter that  was sent to Mr. Cooper in its attempts to collect delinquent consumer debts from other  consumers.     48. The Class consists of more than 35 persons from whom Defendant attempted to collect  delinquent consumer debts by sending other consumers the same form collection letter it  sent to Mr. Cooper.    49. Plaintiff’s claims are typical of the claims of the Class.  Common questions of law or fact  raised by this class action complaint affect all members of the Class and predominate  over any individual issues.  Common relief is therefore sought on behalf of all members  of the Class.  This class action is superior to other available methods for their fair and  efficient adjudication of this controversy.     5. Actual damages under 15 U.S.C. § 1692k(a)(1).     50. The prosecution of separate actions by individual members of the Class would create a  risk of inconsistent or varying adjudications with respect to the individual members of the  Class, and a risk that any adjudications with respect to individual members of the Class  would, as a practical matter, either be dispositive of the interests of other members of the  Class not party to the adjudication, or substantially impair or impede their ability to  protect their interests.  Defendant has acted in a manner applicable to the Class as a  whole such that declaratory relief is warranted.     51. Plaintiff will fairly and adequately protect and represent the interests of the Class.  The  management of the class action proposed is not extraordinarily difficult, and the factual  and legal issues raised by this class action complaint will not require extended contact  with the members of the Class, because Defendant’s conduct was perpetrated on all  members of the Class and will be established by common proof.   Prayer for Relief  WHEREFORE, the Plaintiff, individually and on behalf of all others similarly situated,  prays that the Court grant the following:   6   6. Statutory damages under 15 U.S.C. § 1692k(a)(2)(A).     7. Reasonable attorney’s fees and costs pursuant to 15 U.S.C. § 1692k(a)(3).     8. Such other and further relief as the Court deems just and proper.    Respectfully submitted,  /s/ John T. Steinkamp  John T. Steinkamp  John Steinkamp and Associates  Attorney for Plaintiff  5214 S. East Street, Suite D1  Indianapolis, IN 46227  Office: (317) 780-8300  Fax: (317) 217-1320   Email: john@johnsteinkampandassociates.com    /s/ Andrew A. Ault  Andrew A. Ault  Andrew A. Ault, Esq.  Attorney for Plaintiff  5214 S. East Street, Suite D2  Indianapolis, IN 46227  Office: (317) 866-0948  Email: andrew@aultlawoffice.com    Violation Of § 1692g(a)(2)  Failure To Identify Effectively The Current Creditor   Violation Of § 1692f Of The FDCPA –  Unfair Or Unconscionable Collection Actions   Violation Of § 1692e Of The FDCPA –  False, Deceptive Or Misleading Collection Actions  