 Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ.  P. 23(a) and 23(b)(3).    The Class consists of:   a. all individuals with addresses in the State of Virginia;  b.  to whom Defendant MLR sent an initial collection letter attempting to collect a  consumer debt;  c. that falsely and misleadingly states the consumer’s right to dispute the debt;  d. 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 (2l) days after the filing of this action.    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.    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  Exhibit A, violate 15 U.S.C. §§ l692g, 1692e.    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.    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.   The name of the creditor to whom the debt is owed;    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 June 5, 2020, an obligation was allegedly incurred to ALTEON -  EMA_25_Bon Secours Mary Immaculate Hospital by the Plaintiff.    The ALTEON - EMA_25_Bon Secours Mary Immaculate Hospital obligation arose  out of transactions in which money, property, insurance or services which are the subject of the  transactions were primarily for personal, family or household purposes, specifically medical  services.    The alleged ALTEON - EMA_25_Bon Secours Mary Immaculate Hospital  obligation is a “debt” as defined by 15 U.S.C. §1692a(5).    ALTEON - EMA_25_Bon Secours Mary Immaculate Hospital is a “creditor” as  defined by 15 U.S.C. §1692a(4).    Defendant MLR, a debt collector, was contracted to collect the alleged debt which  originated with ALTEON - EMA_25_Bon Secours Mary Immaculate Hospital.    On or about June 5, 2020, Defendant MLR sent Plaintiff a collection letter (the  “Letter”) regarding the alleged debt currently owed to Defendant ALTEON - EMA_25_Bon  Secours Mary Immaculate Hospital See Exhibit A.    When a debt collector solicits payment from a consumer, it must, within five days  of an initial communication  (1) the amount of the debt;  (2) the name of the creditor to whom the debt is owed;  (3) a statement that unless the consumer, within thirty days after receipt of the notice,  disputes the validity of the debt, or any portion thereof, the debt will be assumed to be  valid by the debt collector;  (4) a statement that if the consumer notifies the debt collector in writing within the thirty- day period that the debt, or any portion thereof, is disputed, the debt collector will obtain  verification of the debt or a copy of the judgment against the consumer and a copy of such  verification or judgment will be mailed to the consumer by the debt collector; and  (5) a statement that, upon the consumer's written request within the thirty-day period, the  debt collector will provide the consumer with the name and address of the original creditor,  if different from the current creditor. 15 U.S.C. § 1692g(a).  These disclosures are commonly known as the “G-Notice.”   A statement that unless the consumer, within thirty days after receipt of  the notice, disputes the validity of the debt, or any portion thereof, the  debt will be assumed to be valid by the debt-collector;    In addition, Defendant’s letter does not advise that that the consumer must dispute  the debt in writing to be provided with the name and address of the original creditor, if  different from the current creditor.    Defendant’s letter merely says: “If you contact this office within 30 days after  receiving this notice, this office will provide you with the name and address of the original  creditor, if different from the current creditor.”    The language “if you contact this office” does not properly convey that the dispute  must be in writing.    These false and inaccurate statements and omissions are deceptive and misleading  as Defendant fails to advise Plaintiff of the proper method for exercising her validation rights  under the FDCPA.    Plaintiff sustained an informational injury as she was not fully apprised of his rights  and responsibilities necessary to exercise her rights under the G-Notice.    Plaintiff effectively waived her rights to this statutorily available information  because she was not properly informed of the G-Notice requirements set forth in the FDCPA.    As a result of Defendant's 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.    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.   A statement that the consumer notifies the debt collector in writing within  thirty-day period that the debt, or any portion thereof, is disputed, the debt  collector will obtain verification of the debt or a copy of a judgment  against the consumer and a copy of such verification or judgment will be  mailed to the consumer by the debt collector; and    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, 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.   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. § 1692g.     Pursuant to 15 USC §1692g, a debt collector:  Within five days after the initial communication with a consumer in connection with  the collection of any debt, a debt collector shall, unless the following information is  contained in the initial communication or the consumer has paid the debt, send the consumer  a written notice containing –    The Defendant violated 15 U.S.C. §1692g, by Falsely and inaccurately stating the  Plaintiff’s rights and responsibilities of the G-Notice as required by the FDCPA.     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.  A statement that, upon the consumer’s written request within the thirty- day period, the debt collector will provide the consumer with the name  and address of the original creditor, if different from the current creditor.   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.  