)  COLLECTIONS, INC.  )  13.  Plaintiff is a natural person allegedly obligated to pay a debt asserted to be owed to a  creditor other than Defendant.   14.  Upon information and belief, on a date better known by Defendant, Defendant began  to attempt to collect an alleged consumer debt from the Plaintiff.    15.  On or about July 30, 2018, Account Services sent the Plaintiff a collection letter. Said  letter is attached and fully incorporated herein as Exhibit A.   16.  Said letter stated “RE: UTSW MEDICAL CENTER”   17.  Upon information and belief, one cannot find any such entity by the name of “UTSW  MEDICAL CENTER” registered with the Texas Secretary of State.1    18.  The letter goes on to state, “Please be advised that your past due account has been  referred to this office for collection by UTSW MEDICAL CENTER.”   20.  This letter does not demonstrate the relationship between Defendant and “UTSW  44.  This action is brought as a class action. Plaintiff brings this action on behalf of herself  and on behalf of all other persons similarly situated pursuant to Rule 23 of the Federal Rules of Civil  Procedure.   45.  The identities of all class members are readily ascertainable from the records of  Account Services and those business and governmental entities on whose behalf it attempts to collect  debts.   46.  Excluded from the Plaintiff's Class is Account Services and all officers, members,  partners, managers, directors, and employees of Account Services, and all of their respective  immediate families, and legal counsel for all parties to this action and all members of their immediate  families.   48.  The Plaintiff's claims are typical of the class members, as all are based upon the same  facts and legal theories.   49.  The Plaintiff will fairly and adequately protect the interests of the Plaintiff's Class  defined in this complaint. The Plaintiff has retained counsel with experience in handling consumer  lawsuits, complex legal issues, and class actions, and neither the Plaintiff nor her attorneys have any  interests, which might cause them not to vigorously pursue this action.   51.  Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil Procedure is  also appropriate in that a determination that the above stated claims, violate provisions of the Fair  Debt Collection Practices Act, and is tantamount to declaratory relief and any monetary relief under  the FDCPA would be merely incidental to that determination.   52.  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's 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.   54.  Depending on the outcome of further investigation and discovery, Plaintiff may, at the  time of class certification motion, seek to certify one or more classes only as to particular issues  pursuant to Fed. R. Civ. P. 23(c)(4).   55.  This cause of action is brought on behalf of Plaintiff and the members of a class.   56.  The class consists of all persons whom Defendant's records reflect resided in the State  of Texas and who were sent a collection letter in substantially the same form letter as the letters sent  to the Plaintiff on or about July 30, 2018 (Exhibit A) and (a) the collection letter was sent to a  consumer seeking to collect a debt for personal, family or household purposes; and (b) the collection  letter was sent from one year before the date of this Complaint to the present; and (c) the collection  letter was not returned by the postal service as undelivered; and (d) the Plaintiff asserts that the letter  contained violations of 15 U.S.C. §§ 1692e, 1692e(10), 1692g and 1692g(a)(2) for failing to correctly  identify the name of the creditor to whom the debt is owed.    57.  Plaintiff incorporates by reference all other paragraphs of this Petition as if fully stated  herein.   58.  Section 1692g of the FDCPA requires that, within 5 days of Defendant’s first  communication to a consumer, it had to provide Plaintiff with an effective validation notice,  containing, among other disclosures, “the name of the creditor to whom the debt is owed” see, 15  U.S.C. § 1692g(a)(2).   60.  Defendant’s violation of § 1692g of the FDCPA renders it liable for actual and  statutory damages, costs, and reasonable attorneys’ fees. See, 15 U.S.C. § 1692k.   61.  Plaintiff incorporates by reference all other paragraphs of this Petition as if fully stated  herein.   62.  Section 1692e of the FDCPA prohibits a debt collector from using any false, deceptive,  or misleading representation or means in connection with the collection of any debt.   63.  Making a false statement of the name of the current creditor violates § 1692e of the  67.  Plaintiff incorporates by reference all other paragraphs of this Petition as if fully stated  herein.   68.  Section 1692d prohibits any debt collector from engaging in any conduct the natural  consequence of which is to harass, oppress, or abuse any person in connection with the collection of  a debt.   69.  Defendant’s communications with Plaintiff were meant to shame, embarrass, and  harass Plaintiff by misrepresenting the alleged debts status.    70.  Section 1692f prohibits the use of unfair and unconscionable means to collect a debt.    71.  Defendant’s communications with Plaintiff were deceptive and misleading.   72.  Defendant used unfair and unconscionable means to attempt to collect the alleged  debt.   Collection Actions   Current Creditor   or Misleading Representation, & Unfair Practices  