11.  Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).   12.  The Class consists of:   a. all individuals with addresses in the State of New York;  b. to whom Defendant EOS sent an initial collection letter;  c. attempting to collect a consumer debt;  d. that states conflicting itemizations of the balance due;  e. which letter was sent on or after a date one (1) year prior to the filing of this  action and on or before a date twenty-one (21) days after the filing of this action.   13.  The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf they attempt to collect and/or have  purchased debts.   14.  Excluded from the Plaintiff Class are the Defendant and all officers, members,  partners, managers, directors and employees of the Defendant and their respective immediate  families, and legal counsel for all parties to this action, and all members of their immediate  families.    16.  The Plaintiff’s claims are typical of the class members, as all are based upon the  same facts and legal theories. The Plaintiff will fairly and adequately protect the interests of the  Plaintiff 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  his attorneys have any interests, which might cause them not to vigorously pursue this action.   18.  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.   19.  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).  21.  Some time prior to June 5, 2020, an obligation was allegedly incurred by Plaintiff  to non-party Verizon Wireless.   22.  The obligation arose out of a transaction in which money, property, insurance or  services of the subject transactions were incurred for personal purposes, specifically personal  credit card purchases.   23.  The alleged Verizon Wireless obligation is a "debt" as defined by 15 U.S.C.§ 1692a  (5).   24.  Verizon Wireless is a "creditor" as defined by 15 U.S.C.§ 1692a (4).   25.  According to Defendant’s letter, Verizon Wireless placed the debt with Defendant  EOS for collection.   26.  Defendant EOS collects and attempts to collect debts incurred or alleged to have  been incurred for personal, family or household purposes on behalf of creditors using the United  States Postal Services, telephone and internet.  Violation - June 5, 2020 Collection Letter   27.  On or about June 5, 2020, Defendant sent Plaintiff an initial collection letter  regarding the alleged debt. See Letter attached as Exhibit A.   28.  The collection letter states:   53.  Plaintiff repeats the above allegations as if set forth here.   54.  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. § 1692e.   55.  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.   56.  Defendant violated said section by:   a. Making a false and misleading representation in violation of §§ 1692e, 1692e  (10) by providing conflicting itemizations of the balance due;  b. Falsely representing the character, amount or legal status of the debt in violation  of §1692e (2).   57.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant’s  conduct violated Section 1692e, et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  59.  Alternatively, 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. § 1692f.   60.  Pursuant to 15 U.S.C. §1692f, a debt collector may not use any unfair or  unconscionable means in connection with the collection of any debt.   61.  Defendant violated this section by unfairly stating conflicting itemizations of the  balance due .    62.  By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant’s  conduct violated Section 1692f, et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  63.  Plaintiff repeats the above allegations as if set forth here.   64.  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.   65.  Pursuant to 15 U.S.C. § 1692g an initial communication with a debtor regarding a  debt must identify the amount of the debt.   66.  Defendant violated this section by failing to clearly state the amount of the debt.   67.  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.  CLIENT ACCOUNT #  PRINCIPAL  INTEREST  FEE  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.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692f et seq.  