13.  The Class satisfies all the requirements of Rule 23 of the FRCP for maintaining a  class action:  • Upon information and belief, the Class is so numerous that joinder of all  members is impracticable because there may be hundreds and/or thousands of  persons who were sent debt collection letters and/or notices from the  Defendants that violate specific provisions of the FDCPA. Plaintiff is  complaining of a standard form letter and/or notice.  (See Exhibit A, except  that the undersigned attorney has, in accordance with Fed. R. Civ. P. 5.2  redacted the financial account numbers and/or personal identifiers in an effort  to protect Plaintiff’s privacy);  • 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:  a.  Whether the Defendants violated various provisions of the  13.  Plaintiff is informed and believes and thereon alleges that all times herein  mentioned each Defendant was acting as the agent, servant, employee, partner, co-conspirator,  and/or joint venturer of each remaining Defendant.  14.  Plaintiff brings this action as a state wide class action, pursuant to Rule 23 of the  Federal Rules of Civil Procedure (hereinafter “FRCP”), on behalf of himself and all City of New  York consumers and their successors in interest (the “Class”), who were sent debt collection  letters and/or notices from the Defendants which are in violation of the FDCPA, as described in  this Complaint.   14.  Plaintiff is at all times to this lawsuit, a "consumer" as that term is defined by 15  U.S.C. § 1692a(3).   15.  Prior to June 3, 2019, Plaintiff incurred a financial obligation to HSBC CARD  33.  Plaintiff, on behalf of himself and others similarly situated, repeats and realleges  all prior allegations as if set forth at length herein.   34.  Collection letters and/or notices, such as those sent by RAUSCH STURM, are to  be evaluated by the objective standard of the hypothetical “least sophisticated consumer.”   36.  Defendants violated 15 U.S.C. §1692g(a)(1)  by sending a letter dated June 3,  2019, to Plaintiff, which failed correctly state the amount of the alleged debt.   37.  The June 3, 2019 letter states: “Total amount of the debt due as [of] the date of  charge-off…………….”   38.  The June 3, 2019 letter provides that there is no amount due as of the charge off  date.   39.  The June 3, 2019 letter further states: “Total amount of interest accrued on the  debt after charge-off…………… $3,843.55”.   40.  The June 3, 2019 letter further states: “Total payments and credits made on the  debt after charge-off…………$4,380.67”.   41.  The June 3, 2019 letter further states: “Balance…..$8,224.22”.   42.  Pursuant to the June 3, 2019 letter, Plaintiff should have a credit balance of  $537.12.    43.  15 U.S.C. §1692e(A)(2) prohibits the false representation of the character, amount  or legal status of any debt.   44.  Defendants violated 15 U.S.C. §1692e(A)(2) by falsely representing the amount  of the debt.   45.  Defendants violated 15 U.S.C. §1692e(A)(2) by falsely representing the  itemization of the debt.   46.  15 U.S.C. §1692e(10) prohibits the use of any false representation or deceptive  means to collect or attempt to collect any debt.   48.  Defendants violated 15 U.S.C. §1692e(10) by by falsely representing the  itemization of the debt.   49.  15 U.S.C. §1692f(1) prohibits a debt collect from collecting any amount, unless  such amount is expressly authorized by the agreement creating the dent or permitted by law.   50.  Defendants violated 15 U.S.C. §1692f(1) by attempting to collect to collect an  amount of $8,224.22, when pursuant to the June 3, 2019 letter, Plaintiff has a credit balance of  $537.12.   51.  Congress enacted the FDCPA in part to eliminate abusive debt collection  practices by debt collectors.   52.  Plaintiff and others similarly situated have a right to free from abusive debt  collection practices by debt collectors.   53.  Plaintiff and others similarly situated have suffered harm as a direct result of the  abusive, deceptive and unfair collection practices described herein.   FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §   1692 et seq.  VIOLATIONS   