 Prior to sending the form letter, Defendant knew: Plaintiff’s home address  and phone number; and upon information and belief, the home address and phone  number of the class members.   Plaintiff brings this action individually, and pursuant to F.Civ.R.P. 23(a),  (b)(2), and (b)(3).  The class under the first claim for relief is defined as:  all Ohio  consumers who have or will receive from Defendant at any time on or after October 10,  2014 the form letter.  The class under the second claim for relief is defined as:  all Ohio  consumers who have or will receive from Defendant at any time on or after October 10,  2013 the form letter.    The members of the class are so numerous that joinder of all parties is  impracticable.  At this time, the precise number cannot be determined.  Upon  information and belief, there appears to be hundreds in the class.    There are questions of law or fact common to the class, including whether  the form letter violates the FDCPA.    Plaintiff’s claims are typical of the class members in that she alleges the  same claims asserted on behalf of the class as a whole.    Plaintiff will fairly and adequately protect the interests of the class in that  she has a personal desire to vindicate the rights of the class and she has retained  competent counsel to represent the class.    Defendant has acted or refused to act on grounds generally applicable to  the class, thereby making appropriate final equitable relief for the class as a whole.  4    Unless Defendant is enjoined and restrained from continuing the foregoing  illegal practices, Plaintiff and the putative class will suffer substantial and irreparable  injury for which they have no adequate remedy at law.    Prosecution of separate actions by individual class members creates risk  of individual adjudications that would, as a practical matter, be dispositive of the  interests of the other members not parties to the adjudication, or would substantially  impair or impede their ability to protect their interests.    Prosecution of separate actions by individual members of the class would  create risk of varying individual adjudications, which would establish incompatible  standards of conduct for defendants who are expected to oppose the class.    Questions of law and fact common to the class members predominate  over any questions affecting only individual members, and a class action is superior to  other methods available for the efficient adjudication of the controversy; the relief sought  by all members of the class will be effective and appropriate for the entire class; all  members of the class have a right to damages or other relief which may be readily  computed in each case or otherwise readily determined.    Many of the persons with whom Defendant has dealt, or who were  affected by its activities, may not be aware of their rights, or are not in a financial  position to assert such rights readily.  Because relegation of their claims to individual  actions would result in an unreasonable multiplicity of suits and a corresponding burden  on this and other courts, a class action is far superior to all other methods for a fair and  efficient adjudication of this controversy.  5   Plaintiff realleges and incorporates by reference all of the allegations  contained in the above paragraphs.    At all times relevant herein, Defendant had Plaintiff’s home address and  phone number.    On or about February 3, 2015, Defendant’s authorized agent, Denise M.  Hayes (“Ms. Hayes”), who at all times relevant herein was acting in the scope of her  authority for Defendant, contacted Plaintiff’s sister.  Ms. Hayes stated it was a personal  matter and left her phone number with extension.     On or about February 11, 2015, Ms. Hayes contacted Plaintiff’s employer  (J.P. Morgan Chase).  Ms. Hayes did not identify herself, or state that se was confirming  or correcting location information concerning Plaintiff.  She stated it was personal.  The  email that Plaintiff received from her employer is attached hereto as Exhibit B.       On or about February 11, 2015, Ms. Hayes contacted Plaintiff by phone on  this date, and stated that she could make substantial payments ($6,000 to $12,000),  which Plaintiff could not make.  Ms. Hayes told her to take out a credit card, ask family  for money or take out a personal loan.  Plaintiff’s offer of $200 per month was  unacceptable, and she asked for more time to try and come up with the money.  Ms.  Hayes gave her through the end of February to do so.      On or about February 25, 2015, Defendant’s authorized agent, Tom  Johnson, who at all times relevant herein was acting in the scope of his authority for  Defendant, called Plaintiff, and left a nasty message that she needed to contact him  before Friday.  He stated, inter alia, that the payment of $200 per month was not  acceptable and that their lawyers would garnish her wages, and that she needed to  6  contact her HR department because there are some employers (reading off a list) that  often fire their employees if they had wage garnishments other than child support.      Upon information and belief, Defendant failed to provide Plaintiff with a  notice of her rights as required by 15 U.S.C. § 1692g.    On or about March 11, 2015, Plaintiff sent Defendant a request for  validation of the debt, a copy of which is attached hereto as Exhibit C, and incorporated  herein by reference.   Defendant has failed to respond to the request for validation.    As a result of Defendant’s actions and inactions, Plaintiff suffered  headaches, embarrassment, anxiety, fear, mental anguish/emotional distress, loss of  sleep, humiliation, worry, outrage, and/or anger.   Plaintiff realleges and incorporates by reference all of the allegations  contained in the above paragraphs.    Defendants routinely sent out the form letter to consumers in an effort to  collect consumer debts in the state of Ohio.      The form letter violated Plaintiff’s and the classes’ rights under the FDCPA  in several ways, including, but not limited to:  a.       Implying that nonpayment of the debt will result in  the seizure, garnishment, attachment of exempt  property in violation of 15 U.S.C. § 1692e(4).  .  b.  Threatening and/or implying to take action it does  not actually intent to take or that it cannot legally  take in violation of 15 U.S.C. § 1692e(5).  c.  Threatening to conduct ASSET DEVELOPMENT  of her/his PLACE OF EMPLOYMENT when it  knew where he/she worked in violation of 15  U.S.C. § 1692b.  7  c.      Threatening to contact relatives and neighbors to  locate consumers, when it knew her/his home  address and phone number in violation of 15  U.S.C. § 1692b.  d.  Threatening and/or implying to contact relatives  and neighbors is a false representation of the  actions that Defendant could legally take in  violation of 15 U.S.C. § 1692e(5).    As a result of Defendant’s actions and inactions, Plaintiff and the class are  entitled to relief as provided for by 15 U.S.C. § 1692k.   Plaintiff realleges and incorporates by reference all of the allegations  contained in the above paragraphs.       At all times relevant herein, Defendant was a supplier under the OCSPA.    The debt arose out of a consumer transaction with a supplier as defined in   Plaintiff realleges and incorporates by references all of the allegations  contained in the above paragraphs.    Defendant’s actions and inactions constitute a violation of common law  invasion of privacy.  See, Housh v. Pleth, 165 Ohio St. 35 (1956).    Defendant’s actions and inactions were intentional, wanton, and/or in  reckless disregard for Plaintiff’s rights.  8    As a result of Defendant’s actions and inactions, Plaintiff is entitled to  actual and punitive damages based upon common law invasion of privacy.   On or about January 23, 2015, Defendant sent Plaintiff the form letter,  which forms the basis of the class claims against Defendant.    The form letter, in an attempt to collect a consumer debt, states:  “Please  call me to discuss repayment options to avoid [“ASSET DEVELOPMENT”] of your:   Under O.R.C § 2329.66, pension accounts, 401k, and deferred  compensation plans are exempt from garnishment and attachment.  Thus, the letter  objectively frustrates a consumer’s ability to intelligently choose his/her response.    The form letter further states that the ASSET DEVELOPMENT search:  “will include contact of your relatives and neighbors to locate you” and that “[t]hese  assets will be used to determine whether to recommend to the creditor legal remedies  to force collection of your debt.”  3   EQUITY, AUTOMBILE EQUITY, PENSION ACCOUNTS, 401K AND  DEFERRED COMPENSATON PLANS, WHOLE LIFE PLANS AND  ANNUITIES.  