 At no time was plaintiff liable for Morrison’s “seizure” or “service” fees, or for  “towing” or “storage” charges, since none of said fees had been approved by the Newton  District Court.      Morrison misrepresented the amount of the debt in violation of 15 U.S.C.  §1692e(2)(A).   The allegations of paragraphs 1 – 14 are incorporated herein as if fully set forth.    By charging plaintiff “seizure” and “service” fees, Morrison misrepresented the  compensation which she could lawfully receive, in violation of 15 U.S.C. §1692e(2)(B).   The allegations of paragraphs 1 – 14 are incorporated herein as if fully set forth.    Morrison used a false representation or deceptive means to collect or attempt to  collect a debt in violation of 15 U.S.C. §1692e(10).   The allegations of paragraphs 1 – 14 are incorporated herein as if fully set forth.    The fees and charges which Morrison charged and collected from plaintiff were not  expressly permitted by any agreement creating the debt (the “debt” having been reduced  to judgment) or Massachusetts law, and Morrison therefore violated 15 U.S.C. §1692f(1).  Class Allegations    There are issues of law and fact common to the class, which issues predominate over  any questions particular to individual class members.  Common issues include whether  defendants are debt collectors under the FDCPA, whether defendants were engaged in  trade or commerce in Massachusetts, whether defendants’ conduct violated the FDCPA  as alleged, and whether defendants may be held jointly and severally liable for harm  suffered by plaintiff and class members.    Plaintiff’s claims are typical in that they arise from the same unlawful conduct as the  claims of class members.  Plaintiff and class members seek, and are entitled to, similar  relief.    A class action is manageable, and is also a superior method for resolving this  controversy since the claims all arise from a standard business practice and class  members are unlikely to file individual actions.  WHEREFORE, plaintiff prays that this Honorable Court:  (i)  certify plaintiff’s claims pursuant to Fed.R.Civ.P. 23;  (ii)  appoint plaintiff as class representative and the undersigned as class  counsel;  (iii)  enjoin defendants from continuing to engage in the unlawful conduct  complained of;  (iv)  rescind all unlawful charges imposed by defendants against class  members;  (v)  award plaintiff and class members actual and statutory damages under the  FDCPA against defendants, jointly and severally;  (vi)  award costs and attorney’s fees against defendants, jointly and severally;  (vii)    award such further relief as shall be just and proper.   Excessive seizure and service fees   The allegations of paragraphs 1 – 14 are incorporated herein as if fully set forth.    If plaintiff was liable to Morrison for any “service fee” or “seizure fee” without the  necessity of court approval, the fees charged by Morrison exceeded any amounts  permitted by Massachusetts law.      As a result of said unlawful conduct, plaintiff suffered financial loss.   The allegations of paragraphs 1 – 14 and 30 are incorporated herein as if fully set  forth.    By charging and collecting from plaintiff the sum of $55.00 as a “service fee” and  the sum of $600.00 as a “seizure fee,” Morrison misrepresented the compensation which  she could lawfully receive in violation of 15 U.S.C. §1692e(2)(B).    As a result of said unlawful conduct, plaintiff suffered financial loss.   The allegations of paragraphs 1 – 14 and 33 are incorporated herein as if fully set  forth.    Morrison used a false representation or deceptive means to collect or attempt to  collect a debt in violation of 15 U.S.C. §1692e(10).    As a result of said unlawful conduct, plaintiff suffered financial loss.   The allegations of paragraphs 1 – 14 and 33 are incorporated herein as if fully set  forth.    The fees which Morrison attempted to collect and did collect from plaintiff were not  expressly permitted by any agreement creating the debt (the “debt” having been reduced  to judgment) or Massachusetts law, and Morrison therefore violated 15 U.S.C. §1692f(1).    Plaintiff brings counts V – VIII of this complaint on behalf of herself and classes of  persons similarly situated, as follows:  Class B  and sub-classes:  “Class B” consists of all Massachusetts residents  whose motor vehicles were seized on execution by Morrison within one year of the filing  of this action pursuant to an execution issued on a judgment on an alleged consumer debt,  and who were charged any “service” or “seizure” fee in excess of that permitted by  Massachusetts law.  Members of “Sub-class B-1” are all members of “Class B” whose  motor vehicles were seized at the request of Forsyth/Brugnoli.  Excluded from each class  and sub-class are defendants and their current and former officers, directors, employees,  and agents.  Plaintiff alleges that the practice described herein is a standard one employed  by defendants and therefore the class is sufficiently numerous such that joinder is  impracticable.    There are issues of law and fact common to the class, which issues predominate over  any questions particular to individual class members.  Common issues include whether  defendants are debt collectors under the FDCPA, whether defendants’ conduct violated  the FDCPA as alleged, and whether defendants may be held jointly and severally liable  for harm suffered by plaintiff and class members..    Plaintiff’s claims are typical in that they arise from the same unlawful conduct as the  claims of class members.  Plaintiff and class members seek, and are entitled to, similar  relief.  