 This action is brought as a class action. Plaintiff brings this action on behalf of herself  and on behalf of all other persons similarly situated pursuant to Rule 23 of the Federal  Rules of Civil Procedure.    The identities of all class members are readily ascertainable from the records of MRS  BPO, L.L.C. and those business and governmental entities on whose behalf it attempts to  collect debts.    Excluded from the Plaintiff's Class is the Defendant and all officers, members, partners,  managers, directors, and employees of MRS BPO, L.L.C., and all of 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's Class, which common  issues predominate over any issues involving only individual class members.  The  principal issues are whether Defendant's communications with the Plaintiff, such as the  above stated claims, violate provisions of the Fair Debt Collection Practices Act.    The Plaintiff's claims are typical of the class members, as all are based upon the same  facts and legal theories.  -6-    The Plaintiff will fairly and adequately protect the interests of the Plaintiff's 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.    This action has been brought, and may properly be maintained, as a class action pursuant  to the provisions of Rule 23 of the Federal Rules of Civil Procedure because there is a  well-defined community interest in the litigation:  (a)  Numerosity: The Plaintiff is informed and believes, and on that basis alleges,  that the Plaintiff's Class defined above is so numerous that joinder of all  members would be impractical.  (b)  Common Questions Predominate: Common questions of law and fact exist  as to all members of the Plaintiff's Class and those questions predominate  over any questions or issues involving only individual class members. The  principal issues are whether the Defendant's communications with the  Plaintiff, such as the above stated claims, violate provisions of the Fair Debt  Collection Practices Act.  (c)  Typicality: The Plaintiff's claims are typical of the claims of the class  members.  Plaintiff and all members of the Plaintiff's Class defined in this  complaint have claims arising out of the Defendant's common uniform  course of conduct complained of herein.  (d)  Adequacy:  The Plaintiff will fairly and adequately protect the interests of  the class members insofar as Plaintiff has no interests that are adverse to the  -7-  absent class members.  The Plaintiff is committed to vigorously litigating  this matter.  Plaintiff has also retained counsel experienced in handling  consumer lawsuits, complex legal issues, and class actions.  Neither the  Plaintiff nor her counsel have any interests, which might cause them not to  vigorously pursue the instant class action lawsuit.  (e)  Superiority: A class action is superior to the other available means for the  fair and efficient adjudication of this controversy because individual  joinder of all members would be impracticable.  Class action treatment  will permit a large number of similarly situated persons to prosecute their  common claims in a single forum efficiently and without unnecessary  duplication of effort and expense that individual actions would engender.  Certification of a class under Rule 23(b)(l)(A) of the Federal Rules of Civil  Procedure is appropriate because adjudications with respect to individual  members create a risk of inconsistent or varying adjudications which could  establish incompatible standards of conduct for Defendant who, on  information and belief, collects debts throughout the United States of  America.    Certification of a class under Rule 23(b)(2) of the Federal Rules of Civil Procedure is   also appropriate in that a determination that the above stated claims, violate provisions of  the Fair Debt Collection Practices Act, and is tantamount to declaratory relief and any  monetary relief under the FDCPA would be merely incidental to that determination.    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  -8-  Plaintiff's 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.    Further, Defendant has acted, or failed to act, on grounds generally applicable to the Rule  (b)(l)(A) and (b)(2) Class, thereby making appropriate final injunctive relief with respect  to the Class as a whole.    Depending on the outcome of further investigation and discovery, Plaintiff may, at the  time of class certification motion, seek to certify one or more classes 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 one (1) through forty six (46) herein with the same force and effect is if the  same were set forth at length herein.    This cause of action is brought on behalf of Plaintiff and the members of a class.    The class involves all individuals whom Defendant's records reflect resided in the State  of New York and who were sent a collection letter in substantially the same form letter as  the letter sent to the Plaintiff on or about May 31, 2017; and (a) the collection letter was  sent to a consumer seeking payment of a personal debt; and (b) the collection letter was  not returned by the postal service as undelivered; and (c) the Plaintiff asserts that the  letter contained violations of 15 U.S.C. §§ 1692e, 1692e(2)(A), 1692e(5), 1692(f), and  1692f(1) for attempting to collect prohibited collection fees.  -9-  Violations of the Fair Debt Collection Practices Act    The Defendant's actions as set forth above in the within complaint violates the Fair Debt  Collection Practices Act.    Because the Defendant violated the Fair Debt Collection Practices Act, the Plaintiff and  the members of the class are entitled to damages in accordance with the Fair Debt  Collection Practices Act.  WHEREFORE, Plaintiff, respectfully requests preliminary and permanent injunctive relief, and that this  Court enter judgment in Plaintiff's favor and against the Defendant and award damages as follows:  (a)  Statutory damages provided under the FDCPA, 15 U.S.C. § 1692(k);  (b)  Attorney fees, litigation expenses and costs incurred in bringing this action; and  (c)  Any other relief that this Court deems appropriate and just under the  circumstances.  Dated: Brooklyn, New York              October 2, 2017      /s/ Maxim Maximov_____  Maxim Maximov, Esq.  Attorneys for the Plaintiff  Maxim Maximov, LLP  1701 Avenue P  Brooklyn, New York 11229  Office: (718) 395-3459  Facsimile: (718) 408-9570  E-mail: m@maximovlaw.com  Plaintiff requests trial by jury on all issues so triable.       /s/ Maxim Maximov_____   Maxim Maximov, Esq.   Violations of the Fair Debt Collection Practices Act brought by Plaintiff on behalf of  herself and the members of a class, as against the Defendant.  