1. The amount of the debt;   13.  Plaintiffs bring 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. §§ 1692e, 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 4, 2020, an obligation was allegedly incurred to  creditor CITIBANK, N.A.   24.  The CITIBANK, N.A. obligation arose out of transactions involving medical  services obtained by Plaintiff from CITIBANK, N.A. and was incurred primarily for personal,  family or household purposes.    25.  The alleged CITIBANK, N.A. obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).   27.  CITIBANK, N.A. purportedly sold the alleged debt to Defendant Cavalry, a debt  collector, who contracted with Defendant FRS to collect the alleged debt.  Violation – November 4, 2020 Collection Letter   28.  On or about November 4, 2020, Defendant FRS sent the Plaintiff a collection letter  (the “Letter”) regarding the alleged debt owed to CITIBANK, N.A. See a true and correct copy  of the letter attached at Exhibit A.   29.  The top of the letter reads:  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;   42.  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.   43.  Defendants’ 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.   44.  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.   46.  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.   47.  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.   48.   Pursuant to 15 USC §1692g, a debt collector:  Within five days after the initial communication with a consumer in connection with  the collection of any debt, a debt collector shall, unless the following information is  contained in the initial communication or the consumer has paid the debt, send the consumer  a written notice containing –   49.  Defendant violated 15 U.S.C. §1692g by failing to clearly communicate the amount  of the debt allegedly owed by Plaintiff.   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.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692g 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.  