10.  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.   11.  Excluded from the Plaintiff Class are the Defendant and all officer, members,  partners, managers, directors and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate  families.    12.  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 Defendant’s letter, violates 15 U.S.C. §§ l692e, and 1692g.   15.  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.   16.  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).  17.  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.   18.  Some time prior to October 17, 2019 an obligation was allegedly incurred to  Desert Springs Hospital.   19.  The Desert Springs Hospital obligation arose out of transactions in which money,  property, insurance or services, which are the subject of the transaction, were primarily for  personal, family or household purposes, specifically medical services.   20.  The alleged Desert Springs Hospital obligation is a "debt" as defined by 15  U.S.C.§ 1692a(5).   22.  Defendant MRS collects and attempts 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 October 17, 2019 Collection Letter   23.  On or about October 17, 2019, Defendant MRS sent Plaintiff a collection letter  (the “Letter”) regarding the alleged debt. See Exhibit A.   24.  When a debt collector solicits payment from a consumer, it must, within five days  of an initial communication, provide the consumer with a written validation notice, known as  a “G notice,” which must include the following information:  (1) the amount of the debt;  (2) the name of the creditor to whom the debt is owed;  (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;  (4) a statement 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 will  obtain verification of the debt or a copy of the judgment against the consumer and a copy  of such verification or judgment will be mailed to the consumer by the debt collector; and  (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. 15 U.S.C. § 1692g(a).  (emphasis added)   26.  However, the next paragraph states in pertinent part: “In order to respect these  important rights provided under the Fair Deb Collection Practices Act, this office will provide  the above rights, whether you provide notice of your dispute orally or in writing, within 30  days from receiving this notice.”   27.  The G- Notice contained in the letter states that a dispute must be in written form  to obtain verification of the debt and to be provided the name and address of the original  creditor.   28.  Yet, the letter further states that a dispute may be made orally, which absolutely  contradicts the information contained in the G-Notice.   29.  This is a false statement and contradicts the rights contained in the G-Notice which  unequivocally states that certain disputes must be in writing.   30.  The least sophisticated consumer reading the two paragraphs could be easily  confused and misled by the contradiction between the G-Notice and the paragraph that  follows the G-Notice.   31.  Defendant could have avoided this confusion by simply not requiring a writing  requirement in the G-Notice and then explaining that they are expanding the rights of the  consumer by allowing oral disputes as well.   32.  Defendant instead chose to insert a template of a G- Notice which blatantly  contradicts the following paragraph.   34.  This false and inaccurate portion of the Letter is deceptive and misleading because  it fails to advise Plaintiff of the proper method for exercising her validation rights under the  38.  Plaintiff repeats, reiterates and incorporates the allegations contained in the  foregoing paragraphs with the same force and effect as if the same were set forth at length  herein.   39.  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.   40.  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.   42.  Due to the fact that Defendant's conduct violated Section 1692e et seq. of the  FDCPA, Defendant is liable to Plaintiff for actual damages, statutory damages, costs and  attorneys’ fees.  43.  Plaintiff repeats, reiterates and incorporates the allegations contained in in the  foregoing paragraphs with the same force and effect as if the same were set forth at length  herein.   44.  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.   46.  Defendant violated this section by deceptively misrepresenting the requirements of  §§1692g(a)(4) and (5) in omitting the requirement that the consumer must dispute or request  information in writing as required under the FDCPA.   47.  Plaintiff sustained an informational injury as her rights were presented in  contradictory fashion.   48.  Due to the fact that Defendant's conduct violated Section 1692g et seq. of the  FDCPA, Defendant is liable to Plaintiff for actual damages, statutory damages, costs and  attorneys’ fees.  8.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   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.  §1692g et seq.  