10.   Plaintiff brings claims, pursuant to the Federal Rules of Civil Procedure  (hereinafter “FRCP”) Rule 23, individually and on behalf of the following nationwide consumer  class (the “Class”):  • Upon information and belief, the Class is so numerous that joinder of all members  is impracticable because there are hundreds and/or thousands of persons who have  received debt collection letters and/or notices from Defendant that violate specific  provisions of the FDCPA. Plaintiff is complaining of a standard form letter and/or  notice that was sent to hundreds of persons (See Exhibit A, except that the  undersigned attorney has, in accordance with Fed. R. Civ. P. 5.2 partially redacted  the financial account numbers in an effort to protect Plaintiff’s privacy);  3  • There are questions of law and fact which are common to the Class and which  predominate over questions affecting any individual Class member.  These  common questions of law and fact include, without limitation:  i. Whether Defendant violated various provisions of the FDCPA;  ii. Whether Plaintiff and the Class have been injured by Defendant’s conduct;  iii. Whether Plaintiff and the Class have sustained damages and are entitled to  restitution as a result of Defendant’s wrongdoing and if so, what is the  proper measure and appropriate statutory formula to be applied in  determining such damages and restitution; and  iv. Whether Plaintiff and the Class are entitled to declaratory and/or injunctive  relief.  • Plaintiff’s claims are typical of the Class, which all arise from the same operative  facts and are based on the same legal theories.  • Plaintiff has no interest adverse or antagonistic to the interest of the other members  of the Class.  • Plaintiff will fairly and adequately protect the interest of the Class and has retained  experienced and competent attorneys to represent the Class.  • A Class Action is superior to other methods for the fair and efficient adjudication of  the claims herein asserted. Plaintiff anticipates that no unusual difficulties are likely  to be encountered in the management of this class action.  • A Class Action will permit large numbers of similarly situated persons to prosecute  their common claims in a single forum simultaneously and without the duplication  4  of effort and expense that numerous individual actions would engender. Class  treatment will also permit the adjudication of relatively small claims by many Class  members who could not otherwise afford to seek legal redress for the wrongs  complained of herein. Absent a Class Action, class members will continue to suffer  losses of statutory protected rights as well as monetary damages. If Defendant’s  conduct is allowed to proceed without remedy they will continue to reap and retain  the proceeds of their ill-gotten gains.  • Defendant has acted on grounds generally applicable to the entire Class, thereby  making appropriate final injunctive relief or corresponding declaratory relief with  respect to the Class as a whole.  11.  Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered “1” through “10” herein with the same force and effect as if the same were set forth at  length herein.   12.  Some time prior to March 6, 2017, an obligation was allegedly incurred by  Plaintiff.   13.  The aforesaid obligation arose out of a transaction in which money, property,  insurance or services, which are the subject of the transaction, are primarily for personal, family or  household purposes.   14.  Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3) of the FDCPA.   15.  Defendant is a “debt collector" as defined by 15 U.S.C. § 1692a(6) of the FDCPA.   16.  At a time known only to Defendant, TJH MEDICAL SERVICES (“Creditor”),  directly or through an intermediary, contracted Defendant to collect on its alleged debt.   17.  In its effort to collect on the Creditor’s agreement, Defendant contacted Plaintiff by  5  written correspondence on March 6, 2017. (See “Exhibit A”).   18.  The letter stated in pertinent part “To avoid further collection, pay it in full.”   19.  Defendant’s written correspondence to Plaintiff is a “communication” as defined by  15 U.S.C. § 1692a(2).   20.  As set forth in the following Counts, Defendant’s communication violated the  CONNECTICUT, INC.,  Defendant.  Plaintiff ESNEDA ZULUAGA (hereinafter, “Plaintiff”), a New York resident, brings  this class action complaint by and through his attorneys, Sirotkin Varacalli & Hamra, LLP,  against Defendant EASTERN ACCOUNT SYSTEM OF CONNECTICUT, INC. (hereinafter  “Defendant”), individually and on behalf of a class of all others similarly situated, pursuant to  Rule 23 of the Federal Rules of Civil Procedure, based upon information and belief of  Plaintiff’s counsel, except for allegations specifically pertaining to Plaintiff, which are based  upon Plaintiff’s personal knowledge. 