 Plaintiffs bring 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 New York;  b. that have received collection attempts from Portfolio Recovery Associates, LLC,  for debts originating with Synchrony Bank, while said consumers were in  Disaster Areas as designated by FEMA or State Governments for debts incurred  for personal, familial, or household use,   c. 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.    Excluded from the Plaintiff Classes 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 Classes, 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. §§ l692e, 1692f.    The Plaintiffs' claims are typical of the class members, as all are based upon the same  facts and legal theories. The Plaintiffs will fairly and adequately protect the interests of the  Plaintiff Classes defined in this complaint. The Plaintiffs have retained counsel with experience  in handling consumer lawsuits, complex legal issues, and class actions, and neither the Plaintiffs  nor their 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 Plaintiffs are informed and believe, and on that basis allege,  that the Plaintiff Classes defined above are 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 Classes and those questions predominance over  any questions or 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 USC §§ l692e,1692f.  c. Typicality: The Plaintiffs’ claims are typical of the claims of the class members.  The Plaintiffs and all members of the Plaintiff Classes have claims arising out of  the Defendants' common uniform course of conduct complained of herein.  d. Adequacy: The Plaintiffs will fairly and adequately protect the interests of the  class members insofar as Plaintiffs have no interests that are adverse to the absent  class members. The Plaintiffs are committed to vigorously litigating this matter.  Plaintiffs have also retained counsel experienced in handling consumer lawsuits,  complex legal issues, and class actions. Neither the Plaintiff nor his 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)(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  Classes 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.    Depending on the outcome of further investigation and discovery, Plaintiffs 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 April 14, 2020, an obligation was allegedly incurred to Synchrony  Bank by the Plaintiff.    The Synchrony Bank obligation arose out of credit card transactions in which money,  property, insurance or services, which are the subject of the transaction, were primarily for  personal, family or household purposes.    The alleged Synchrony Bank obligation is a "debt" as defined by 15 U.S.C.§  1692a(5).    Sometime thereafter, Defendant PRA purportedly purchased the alleged debt and is  collecting the alleged debt.    Defendant PRA 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  – April 14, 2020 Collection Letter    On or about April 14, 2020, Defendant sent the Plaintiff a collection letter (the  “Letter”) regarding the alleged debt owed to PRA.  See Letter attached as Exhibit A.    Upon information and belief, PRA purchased Plaintiff’s alleged debt from  Synchrony Bank and the sale of this alleged debt is subject to relevant conditions that Synchrony  Bank imposes on its debt purchasers.    Synchrony Bank contracts of sale (a/k/a Forward Flow Agreements) for defaulted  debt provide specific limitation on the ability of its debt purchasers to make any collection  attempts while alleged debtors are in disaster areas as determined by FEMA or any other  appropriate government entity.    Accordingly, upon information and belief, PRA purchased Plaintiff’s alleged debt  from Synchrony Bank and the Forward Flow Agreements evidencing proof of sale, prohibits  PRA from seeking to collect against Plaintiff’s alleged debt, while Plaintiff resides in a disaster  area.    The state of affairs in New York, and frankly the whole world, is well known. The  Covid-19 pandemic has wreaked havoc across the world, the United States, and New York.    On March 7, 2020, Governor Cuomo declared a State of Emergency across the entire  State.    On March 13, 2020, President Donald Trump declared a nationwide emergency,  including for the State of New York, as recognized by the Federal Register.    Despite the fact that Plaintiff clearly resided in a disaster area in April 2020, PRA  pursued collection activities by sending collection letters to Plaintiff.    Given the express conditions of sale, PRA misrepresented its ability to collect  Plaintiff’s debt by sending collection letters in April 2020. Accordingly, PRA has violated the   Plaintiff incorporates by reference paragraphs 1-36 of this Complaint as though fully  stated 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, e(2),  e(5), e(10), and f.    By reason thereof, Defendant is liable to Plaintiff for judgment that Defendant's  conduct violated Section 1692e, et seq. of the FDCPA and is entitled to actual damages, statutory  damages, costs and attorneys’ fees.  VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT   15 U.S.C. §1692e et seq.  