 Plaintiffs bring this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).    The identities of all class members are readily ascertainable from the records of  Defendant and those companies and entities on whose behalf it attempts to collect debts and/or  has purchased debts.    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.     There are questions of law and fact common to the Plaintiff Class, which common  issues predominate over any issues involving only individual class members. The principal  issue is whether the Defendant’s written communications to consumers, in the forms attached  as Exhibits A, violate 15 U.S.C. §§ 1692e.    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 in that a class action  is superior to other available methods for the fair and efficient adjudication of the controversy.    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).   Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  numbered above herein with the same force and effect as if the same were set forth at length  herein.    Some time prior to March 31, 2020, an obligation was allegedly incurred to  Citibank, N.A./Best Buy.    The alleged Citibank, N.A./Best Buy obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).    Citibank, N.A./Best Buy is a "creditor" as defined by 15 U.S.C. § 1692a(4).    Defendant Cavalry purportedly purchased the rights to collect the Citibank,  N.A./Best Buy debt who contracted with Defendant C&B to collect the alleged debt.    Defendant 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  – March 31, 2020 Collection Letter    On or about March 31, 2020, Defendant C& B sent the Plaintiff a collection letter  (the “Letter”) on behalf of the Defendant Cavalry regarding the alleged debt owed to Citibank,  N.A./Best Buy. A true and correct copy of the Letter is attached hereto as Exhibit A.    The Letter lists a balance of $3,347.65.    The letter offers various offers of settlement on the full balance.    The letter offers a “3 Month Payment Plan” and offers the following terms:  “Take $502.15 off the balance. Pay 3 equal monthly installments of $948.50.  First Payment due no later than 05/15/20 and every 30 days thereafter.  Your  account will be considered “Settled in Full” after we post your final payment.”    The letter states that the first payment is due no later than 05/15/20 and every 30  days thereafter.    The letter is confusing and deceptive by offering a settlement agreement with  unclear terms as to due date of the payments.      This could easily confuse and deceive the consumer as the Letter does not indicate  whether the payment is due on the 15th of each month or within 30 days of the last payment.     This language is false and deceptive as Plaintiff was unable to determine when the  settlement payments would be due.    Defendants’ collection efforts with respect to this alleged debt from Plaintiff caused  Plaintiff to suffer concrete and particularized harm because the FDCPA provides Plaintiff with  the legally protected right to be not to be misled or treated unfairly with respect to any action  for the collection of any consumer debt.    Defendants’ deceptive, misleading and unfair representations with respect to its  collection effort were material misrepresentations that affected and frustrated Plaintiff's ability  to intelligently respond to Defendants’ collection efforts because Plaintiff could not adequately  respond to the Defendants’ demand for payment of this debt.    Defendants’ actions created an appreciable risk to Plaintiff of being unable to  properly respond or handle Defendants’ debt collection.    Plaintiff was confused and misled to her detriment by the statements in the dunning  letter, and relied on the contents of the letter to her detriment.    Plaintiff would have pursued a different course of action were it not for the statutory  violation(s).    As a result of Defendants’ deceptive, misleading and unfair debt collection   practices, Plaintiff has been damaged.   Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs  above herein with the same force and effect as if the same were set forth at length herein.    Defendants’ 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.    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.    Defendant violated § 1692e:   a. As the Letter it is open to more than one reasonable interpretation, at least one  of which is inaccurate.  b. By making a false and misleading representation in violation of §1692e(10).    By reason thereof, Defendants are liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, and Plaintiff is entitled to an award of  actual damages, statutory damages, costs and attorneys’ fees. 