 Plaintiff brings 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  Defendants and those companies and entities on whose behalf they attempt to collect and/or  have purchased debts.    Excluded from the Plaintiff Class are the Defendants and all officer, members,  partners, managers, directors and employees of the Defendants 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 Defendants' written communications to consumers, in the forms attached as  Exhibits A, violate 15 U.S.C. §§ l692e and 1692f.    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 her attorneys have any interests, which might cause them not to vigorously pursue this  action.    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 May 3, 2019, an obligation was allegedly incurred by Plaintiff.    The alleged obligation arose out of a transaction involving a debt allegedly incurred  by Plaintiff with Augusta, Realtors in which the subject of the transaction was primarily for  personal, family or household purposes.    The alleged obligation is a "debt" as defined by 15 U.S.C.§ 1692a(5).    The owner of the alleged obligation is a "creditor" as defined by 15 U.S.C.§ 1692a(4).    The owner of the obligation contracted with the Defendant Hunter to collect the  alleged debt.    On or about May 3, 2019, Defendant sent the Plaintiff a collection letter (the  “Letter”) seeking to collect an alleged debt.  See Collection Letter – Attached hereto as  Exhibit A.    The letter warned:   “Your account is now in final review.  This account meets the guidelines for legal action set  by the creditor, but they have not yet referred your account to an attorney or made a decision  to file a lawsuit. …  If we cannot resolve this matter, the creditor may refer your account to  an attorney to review their ability to recover your unpaid balance through litigation.  If an  action is commenced and a judgment is sought, you will be given notice and the opportunity  to raise a legal defense. Accordingly, demand is hereby made for full payment of your past  due amount to avoid the possibility of additional costs if the creditor chooses to proceed with  legal action.”    The threat that Plaintiff’s account is in “final review” and “meets the guidelines for  legal action” is harassing and only serves to scare Plaintiff into making immediate payment.    Further, the implication is that litigation is imminent, due to the account “meeting  the guidelines for legal action,” yet the Defendant is not an attorney and cannot make the  decision if and when a lawsuit may occur.    In addition, neither the Defendant nor the creditor are attorneys, yet the letter goes  into detail regarding the legal process discussing what the attorney will be reviewing in  litigation, legal defenses and possibilities of additional costs through litigation, all in furtherance  of harassing and  intimidating the Plaintiff into making an immediate payment due to fear of  litigation and higher costs and fees.    These threats only serve to coerce Plaintiff into paying immediately to avoid the  threat of legal action.      As a result of Defendant’s deceptive misleading and false 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.    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.    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 said section   a.  by making a false and misleading representation in violation of §1692e(10);  b.  by falsely representing the character, amount of legal status of the debt in  violation of §1692e(2)(A);   c.  my making the threat to take any action that cannot legally be taken or that is  not intended to be taken in violation of §1692e(5).    By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.   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.    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.    Defendant violated this section by falsely threatening and harassing Plaintiff with the  letter containing false threats.    By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692f et seq. of the FDCPA, actual damages, statutory damages, costs  and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C.  §1692f et seq.   VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. §1692e  et seq.  