10.  Defendant sought to collect a consumer debt from Plaintiff arising from a medical  debt.  The debt was incurred primarily for personal, household or family use.  The debt was not  incurred for any commercial purpose.    11.  On or about June 16, 2016, Defendant mailed Plaintiff a demand letter seeking  payment of an alleged debt.  (The “Demand Letter” is attached hereto as “Exhibit 1”).    12.  The Demand Letter states in part:   Nuestra empresa es MFMI Collection Service, Inc.   xxxx  A menos que usted cuestione la validez de la deuda o cualquier parte  de la misma, dentro de treinta días a partir de la fecha en que recibe  este aviso, MFMI Collection Service, Inc. supondrá que la deuda es  válida.  Usted debe informarnos por escrito dentro de ese período  de 30 días si va a cuestionar esta deuda.  Obtendremos la  verificación de la deuda o una copia de una sentencia en su contra y  le enviaremos una copia de dicha verificación o sentencia.    (emphasis added).    14.  The reverse side of page 1 of the Demand Letter states in part:   Por favor, envíe su pago entre 21 días.    15.  Translated to English the reverse side of page 1 of the Demand Letter states in part:  Please send your payment within 21 days.   16.  The Demand Letter is on the letter head of MFMI, Inc.  The Demand Letter is  addressed from MFMI, Inc.     17.  The Demand Letter states that the Demand Letter is from “MFMI Collection  Service, Inc.” and that it is from “MFMI Collection Service.”    18.  MFMI, Inc. is not an existing corporation.   19.  MFMI, Inc. does not have a consumer debt collection license as mandated by  Florida Statutes § 559.553.   20.  MFMI Collection Service is not an existing business entity.   21.  MFMI Collection Service was registered as a fictitious name in Florida in 1992.   The owner of the fictitious name was Defendant, Medical & Financial Management, Inc.   22.  The registration of the fictitious name MFMI Collection Service expired in 2007.   23.  MFMI Collection Service does not have a consumer debt collection license as  mandated by Florida Statutes § 559.553.   25.  MFMI Collection Service, Inc. does not have a consumer debt collection license as  mandated by Florida Statutes § 559.553.    26.  The name of the debt collector Defendant, Medical & Financial Management, Inc.,  does not appear anywhere on the Demand Letter.    27.  The Demand Letter was Defendant’s initial communication with Plaintiff with  respect to the debt alleged therein.    29.  Defendant’s failure to obtain a consumer debt collection license as mandated by  Florida Statutes § 559.553, for MFMI, Inc., MFMI Collection Service and/or MFMI Collection  Service, Inc., while actively engaging in debt collection while using the names MFMI, Inc., MFMI  Collection Service, and/or MFMI Collection Service, Inc., violates the FDCPA.    30.  Defendant’s demand for payment within 21 days overshadows Plaintiff’s 30 day  dispute period and therefore violates the FDCPA.    31.  Defendant’s statement that Plaintiff “must” (“debe”) notify the Defendant in  writing is false and misleading and therefore a violation of the FDCPA as 15 U.S.C. § 1692g(a)(3)  contains no writing requirement in order for the Plaintiff to dispute the debt.    32.  Defendant’s omission of the phrase that Plaintiff may dispute “any portion thereof”  of the debt, as stated in 15 U.S.C. § 1692g(a)(4) is a violation of the FDCPA.   33.  Defendant’s statement “Obtendremos la verificación de la deuda o una copia de una  sentencia en su contra y le enviaremos una copia de dicha verificación o sentencia.” (We obtain  verification of the debt or a copy of a judgment against you and send you a copy of such  verification or judgment.) is false and misleading and therefore a violation of the FDPCA as 15  U.S.C. § 1692g(a)(4) requires Plaintiff to request verification of the debt in writing.   35.  The Defendant’s Demand Letter fails to disclose that the Defendant is a debt  collector, that the letter is an attempt to collect a debt, and that any information obtained will be  used to that purpose as required by 15 U.S.C. § 1692e(11), and is therefore a violation of the  39.  Plaintiff alleges on information and belief that Defendant’s practice of sending  initial communication letters that were purported to be sent by MFMI, Inc. and did not contain  the disclosures required by 15 U.S.C. § 1692g(a) and 15 U.S.C. § 1692e served upon the Class is  so numerous that joinder of all members of the Class is impractical.   40.  There are questions of law or fact common to the Class.  The common issues  predominate over any issues involving only individual Class members.  The common legal and  factual issue to each Class member is that each was mailed or delivered an initial communication  letter by Defendant that purported to be sent by MFMI, Inc. and did not contain the disclosures  required by 15 U.S.C. § 1692g(a) and 15 U.S.C. § 1692e.    41.  Plaintiff’s claim is typical of those of the Class members.  All are based on the same  facts and legal theories.   43.  Certification of the Class under Rule 23(b)(3) of the Federal Rules of Civil  Procedure is also appropriate in that:  (1) The questions of law or fact common to the members of the  class predominate over any questions affecting an individual  member.  (2) A class action is superior to other available methods for the fair  and efficient adjudication of the controversy.   44.  Plaintiff requests certification of a Class under Rule 23(b)(3), of the Federal Rules  of Civil Procedure, for monetary damages; her appointment as Class Representative; and that her  attorney Leo W. Desmond be appointed Class Counsel.  45.  Plaintiff re-alleges Paragraphs 1 through 37.   47.  Pursuant to the FDCPA, the Demand Letter was an initial communication between  Defendant and Plaintiff.   48.  Defendant’s Demand Letter did not contain the disclosures required by the 15  U.S.C. § 1692g(a) and 15 U.S.C. § 1692e of FDCPA.   Defendant has attempted to mislead the  Plaintiff and the Class into believing that the Demand Letter contained the proper notice required  under the FDCPA.    49.  Defendant’s Demand Letter would be misleading to the least sophisticated  consumer with regard to his/her legal rights as it incorrectly omits that the consumer may dispute  any portion of the debt, despite the clear wording of 15 U.S.C. § 1692g(a)(4).     50.  Defendant’s statement that Plaintiff “debe” (must) notify the Defendant in writing  is false and misleading and therefore a violation of the FDCPA as 15 U.S.C. § 1692g(a)(3)  contains no writing requirement in order for the consumer to dispute the debt or any portion  thereof.   52.  Defendant’s Demand Letter requests payment of the debt within 21 days.   53.  Defendant’s demand for payment within 21 days overshadows Plaintiff’s 30 day  dispute period and therefore violates 15 U.S.C. § 1692g.    54.  As a result of Defendant’s conduct, Plaintiff and the Class are entitled to an award  of statutory damages pursuant to 15 U.S.C. §1692k.   55.  As a result of Defendant’s conduct, Plaintiff and the Class are entitled to an award  of costs and attorney’s fees pursuant to 15 U.S.C. §1692k.  56.  Plaintiff re-alleges Paragraphs 1 through 37 and 46 through 53.   58.  Defendant sent a Demand Letter to Plaintiff that was an initial communication used  in the collection of a debt between Defendant and Plaintiff.   59.  The Demand Letter is on the letter head of MFMI, Inc.  The Demand Letter is  addressed from MFMI, Inc.     60.  The Demand Letter also claims to be from MFMI Collection Service and MFMI  Collection Service, Inc.   61.  MFMI, Inc. is not an existing corporation.   62.  MFMI, Inc. does not have a consumer debt collection license as mandated by  Florida Statutes § 559.553.   63.  MFMI Collection Service is not an existing business entity.   64.  MFMI Collection Service does not have a consumer debt collection license as  mandated by Florida Statutes § 559.553.    66.  MFMI Collection Service, Inc. does not have a consumer debt collection license as  mandated by Florida Statutes § 559.553.   67.  The name of the debt collector Defendant, Medical & Financial Management, Inc.,  does not appear anywhere on the Demand Letter.   68.  The Defendant’s Demand Letter purports to be from MFMI, Inc., MFMI Collection  Service, Inc. and/or MFMI Collection Service, none of which is the true name of Defendant  Medical & Financial Management, Inc., and is therefore a violation of 15 U.S.C. § 1692e(14).   69.  Defendant’s failure to obtain a consumer debt collection license as mandated by  Florida Statutes § 559.553, for MFMI, Inc., MFMI Collection Service and/or MFMI Collection  Service, Inc., while actively engaging in debt collection while using the names MFMI, Inc. and  MFMI Collection Service and/or MFMI Collection Service, Inc., violates 15 U.S.C. § 1692e.    70.  Defendant’s statement that Plaintiff “debe” (must) notify the Defendant in writing  is misleading and confusing as 15 U.S.C. § 1692g(a)(3) contains no writing requirement to dispute  the debt, and therefore violates 15 U.S.C. § 1692e    71.  Defendant’s omission of the phrase that Plaintiff may dispute “any portion thereof”  of the debt, as stated in 15 U.S.C. § 1692g(a)(4) is misleading and confusing and therefore violates  15 U.S.C. § 1692e.     73.  Defendant’s Demand Letter would be deceptive to the least sophisticated consumer  with regard to his/her legal rights.    74.  As a result of Defendant’s conduct, Plaintiff and the Class are entitled to an award  of statutory damages pursuant to 15 U.S.C. § 1692k.   75.  As a result of Defendant’s conduct, Plaintiff and the Class are entitled to an award  of costs and attorney’s fees pursuant to 15 U.S.C. § 1692k.  VIOLATION OF 15 U.S.C. § 1692g(a)   VIOLATION OF 15 U.S.C. § 1692e  