1. The amount of the debt;   13.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   15.  The identities of all class members are readily ascertainable from the records of  Defendants and those companies and entities on whose behalf they attempt to collect and/or  have purchased debts.   16.  Excluded from the Plaintiff Class are the Defendants and all officer, members,  partners, managers, directors and employees of the Defendants and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate  families.    17.  There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal issue  is whether the Defendants' written communications to consumers, in the forms attached as  Exhibit A, violate 15 U.S.C. §§ l692e, 1692d, 1692f, 1692g.   2. The name of the creditor to whom the debt is owed;   20.  Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure  is also appropriate in that the questions of law and fact common to members of the Plaintiff  Class predominate over any questions affecting an individual member, and a class action is  superior to other available methods for the fair and efficient adjudication of the controversy.   21.  Depending on the outcome of further investigation and discovery, Plaintiff may, at  the time of class certification motion, seek to certify a class(es) only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).  22.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.   23.  Some time prior to November 7, 2019, an obligation was allegedly incurred to  Pentagon Federal Credit Union by the Plaintiff.   24.  The Pentagon Federal Credit Union obligation arose out of transactions in which  money, property, insurance or services which are the subject of the transactions were primarily  for personal, family or household purposes.   26.  Pentagon Federal Credit Union is a “creditor” as defined by 15 U.S.C. §1692a(4).   27.  Sometime thereafter, Defendant UHG purportedly purchased the alleged debt.   28.  Defendant Eastpoint, a debt collector, was contracted by Defendant UHG, to collect  the alleged debt which originated with Pentagon Federal Credit Union   29.  Defendants Eastpoint and Defendants UHG collect and attempt to collect debts  incurred or alleged to have been incurred for personal, family or household purposes on behalf  of creditors using the United States Postal Services, telephone and internet.  Violation I – November 7, 2019  Collection Letter   3. A statement that unless the consumer, within thirty days after receipt of  the notice, disputes the validity of the debt, or any portion thereof, the  debt will be assumed to be valid by the debt-collector;   30.  On or about November 7, 2019 Defendant Eastpoint sent Plaintiff a collection letter  (the “Letter”) regarding the alleged debt currently owed to Pentagon Federal Credit Union See  Exhibit A.   32.  The FDCPA further provides 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 shall cease collection . . . until the debt collector obtains verification of the  debt . . . and a copy of such verification is mailed to the consumer by the debt collector.'' 15  U.S.C. § 1692g(b).   33.  Although a collection letter may track the statutory language, ''the collector  nevertheless violates the Act if it conveys that information in a confusing or contradictory  fashion so as to cloud the required message with uncertainty.'' Russell v. EQUIFAX A.R.S., 74  F.3d 30, 35 (2d Cir. 1996) (''It is not enough for a debt collection agency to simply include the  proper debt validation notice in a mailing to a consumer-- Congress intended that such notice  be clearly conveyed.''). Put differently, a notice containing ''language that 'overshadows or  contradicts' other language informing a consumer of her rights . . . violates the Act.'' Russell,  74 F.3d at 34.   34.  The letter states: “The account listed above has been assigned to this agency for  collection.  We are a professional collection agency attempting to collect a debt.  Any  information we obtain will be used as a basis to enforce a collection of this debt.”   35.   This statement is threatening and confusing to the Plaintiff by saying that any  information obtained will be used to enforce a collection of this debt.   37.  This language completely overshadows the “G-Notice” by scaring Plaintiff into  making payment immediately to avoid the means of enforcement threatened by the Defendant  instead of exercising his statutory right to dispute the debt as provided by the FDCPA.   38.  The letter is confusing and threatening to Plaintiff, causing distress and anxiety  leading Plaintiff to retain an attorney to help him defend his rights as a consumer.   39.  As a result of Defendant's deceptive, misleading and unfair debt collection practices,  Plaintiff has been damaged.  4. A statement that the consumer notifies the debt collector in writing within  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; and   40.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   41.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692e.   42.  Pursuant to 15 U.S.C. §1692e, a debt collector may not use any false, deceptive, or  misleading representation or means in connection with the collection of any debt.   43.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  44.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   45.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692d.   46.  Pursuant to 15 U.S.C. §1692d, a debt collector may not engage in any conduct the  natural consequence of which is to harass, oppress, or abuse any person with the collection of  the debt.   47.  Defendant violated said section by harassing and oppressing Plaintiff by harassing  him with threatening language.   48.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692d et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  49.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.   5. A statement that, upon the consumer’s written request within the thirty- day period, the debt collector will provide the consumer with the name  and address of the original creditor, if different from the current creditor.   50.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692g.   52.  The Defendant violated 15 U.S.C. §1692g, with threatening language, which  overshadows the ''g-notice'' language and coerces the consumer not to exert its rights under the  55.  Defendant’s debt collection efforts attempted and/or directed towards the Plaintiff  violated various provisions of the FDCPA, including but not limited to 15 U.S.C. § 1692f.   56.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   57.  Defendant violated this section by falsely threatening and harassing Plaintiff with a  letter containing threatening language.   58.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692g et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692f et seq.  