12.  Defendants sought to collect from Plaintiff an alleged debt incurred by Plaintiff for  personal, family, or household purposes; more specifically, the debt at issue was a delinquent  medical debt.  3   13.  Defendant Pendrick purchases debt from original creditors while the debt is in  default with the original creditor, and then attempts to collect on the purchased debt.   14.  Defendant Pendrick purchased Plaintiff’s underlying debt while the debt was in  default with the original creditor.   15.  On or about November 8, 2016, Defendant Affiliate, acting as an agent for  Defendant Pendrick, sent a demand letter to Plaintiff seeking to collect an alleged debt owned by  Defendant Pendrick.  (The “Demand Letter”, attached hereto as “Exhibit 1”).   16.  The Demand Letter was Defendant Affiliate’s initial communication with respect  to the debt alleged therein.    17.  The Demand Letter stated in part:   25.  This action is brought on behalf of a Class consisting of (i) all persons with  addresses in the State of Florida (ii) to whom initial communication letters that contained the  language: “UNLESS YOU NOTIFY THIS OFFICE IN WRITING WITHIN 30 DAYS  32.  Plaintiff re-alleges and incorporates Paragraphs 1 through 24.   33.  15 U.S.C. §1692g(a)(3) states after an initial communication the Defendants must  provide Plaintiff with:   (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;    34.  Defendants mailed, delivered, or caused to be mailed or delivered, the Demand  Letter to Plaintiff on behalf of Defendant Pendrick in an attempt to collect a consumer debt, namely  to collect an alleged medical debt that was in default with the original creditor when purchased by  Defendant Pendrick.  9   35.  By claiming to have given Plaintiff the information required by the FDCPA,  Defendants have attempted to mislead Plaintiff and the Class into believing that the Demand Letter  contained the proper notice required under the Fair Debt Collection Practices Act.   36.  Defendants’ Demand Letter states the consumer must dispute the debt in writing  despite the clear wording of 15 U.S.C. §1692g(a)(3), which contains no writing requirement in  order for the consumer to dispute the debt.   37.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of statutory damages pursuant to 15 U.S.C. §1692k.   38.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of costs and attorney’s fees pursuant to 15 U.S.C. §1692k.  39.  Plaintiff re-alleges and incorporates Paragraphs 1 through 24 and 33 through 36.   40.  15 U.S.C. §1692g(a)(4) states after an initial communication the Defendants must  provide Plaintiff with:   (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 a judgment against the consumer and a copy of such  verification or judgment will be mailed to the consumer by the debt  collector; and    41.  Defendants mailed, delivered, or caused to be mailed or delivered, the Demand  Letter to Plaintiff on behalf of Defendant Pendrick in an attempt to collect a consumer debt, namely  to collect an alleged medical debt purchased by Defendant Pendrick while the debt was in default  with the original creditor.  10   42.  By claiming to have given Plaintiff the information required by the FDCPA,  Defendants have attempted to mislead Plaintiff and the Class into believing that the Demand Letter  contained the proper notice required under the Fair Debt Collection Practices Act.   43.  Defendants’ Demand Letter omits to inform the consumer that he or she must  dispute the debt in writing despite the clear wording of 15 U.S.C. §1692g(a)(4) which requires  requests of verification of the debt to be in writing in order for the consumer to receive verification  of the debt or a copy of a judgment, should a judgment exist.    44.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of statutory damages pursuant to 15 U.S.C. §1692k.   45.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of costs and attorney’s fees pursuant to 15 U.S.C. §1692k.  46.  Plaintiff re-alleges and incorporates Paragraphs 1 through 24, 33 through 36, and  40 through 43.   47.  15 U.S.C. §1692g(a)(5) states after an initial communication the Defendants must  provide Plaintiff with:   (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.    48.  Defendants mailed, delivered, or caused to be mailed or delivered, the Demand  Letter to Plaintiff on behalf of Defendant Pendrick in an attempt to collect a consumer debt, namely  to collect an alleged medical debt purchased by Defendant Pendrick while the debt was in default  with the original creditor.  11   49.  By claiming to have given Plaintiff the information required by the FDCPA,  Defendants have attempted to mislead Plaintiff and the Class into believing that the Demand Letter  contained the proper notice required under the Fair Debt Collection Practices Act.   50.  Defendants’ Demand Letter omits to inform the consumer that he or she must  request the name of the original creditor in writing despite the clear wording of 15 U.S.C.  §1692g(a)(5), which requires requests of the name of the creditor to be in writing in order for the  consumer to receive the name of the original creditor, if different from the current creditor.    51.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of statutory damages pursuant to 15 U.S.C. §1692k.   52.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of costs and attorney’s fees pursuant to 15 U.S.C. §1692k.  53.  Plaintiff re-alleges and incorporates Paragraphs 1 through 24, 33 through 36, 40  through 43, and 47 through 50.   54.  15 U.S.C. §1692e states:  A debt collector may not use any false, deceptive, or misleading  representation or means in connection with the collection of any  debt.  Without limiting the general application of the foregoing, the  following conduct is a violation of this section:  xxxx  (10) The use of any false representation or deceptive  means to collect or attempt to collect any debt or to  obtain information concerning a consumer.    55.  Defendants mailed, delivered, or caused to be mailed or delivered the Demand  Letter to Plaintiff on behalf of Defendant Pendrick in connection with an attempt to collect a  12  consumer debt, namely to collect an alleged medical debt purchased by Defendant Pendrick while  the debt was in default with the original creditor.   56.  Defendants’ Demand Letter incorrectly states that Plaintiff and the Class must  dispute the debt in writing despite the clear wording of 15 U.S.C. §1692g(a)(3), which contains no  writing requirement in order for the consumer to dispute the debt.   57.  Defendants’ Demand Letter would be confusing and misleading to the least  sophisticated consumer with regard to his/her legal rights as it states that the Plaintiff and the Class  have to dispute the debt in writing despite the clear wording of 15 U.S.C. §1692g(a)(3), which  contains no writing requirement in order for the consumer to dispute the debt.     58.  Defendants’ Demand Letter omits to inform the consumer that he or she must  dispute the debt in writing despite the clear wording of 15 U.S.C. §1692g(a)(4), which requires  requests of verification of the debt to be in writing in order for the consumer to receive verification  of the debt or a copy of a judgment, should a judgment exist.    59.  Defendants’ Demand Letter omits to inform the consumer that he or she must  request the name of the original creditor in writing despite the clear wording of 15 U.S.C.  §1692g(a)(5), which requires requests of the name of the creditor to be in writing in order for the  consumer to receive the name of the original creditor, if different from the current creditor.    60.  By claiming to have given Plaintiff the information required by the FDCPA,  Defendants have attempted to mislead the Plaintiff and the Class into believing that the Demand  Letter contained the proper notice required under the Fair Debt Collection Practices Act.   61.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of statutory damages pursuant to 15 U.S.C. §1692k.   62.  As a result of Defendants’ conduct, Plaintiff and the Class are entitled to an award  of costs and attorney’s fees pursuant to 15 U.S.C. §1692k.  13  AS TO DEFENDANTS   VIOLATION OF 15 U.S.C. §1692g(a)(4)  CLASS CLAIM AGAINST DEFENDANTS    VIOLATION OF 15 U.S.C. §1692g(a)(3)  CLASS CLAIM AGAINST DEFENDANTS   VIOLATION OF 15 U.S.C. §1692e  CLASS CLAIM AGAINST DEFENDANTS    VIOLATION OF 15 U.S.C. §1692g(a)(5)  CLASS CLAIM AGAINST DEFENDANTS  