On or around July 1, 2015, Plaintiff answered one of Defendant’s phone calls and spoke with “E.F. Haskins.” Mr. Haskins told Plaintiff that there was a warrant out for her arrest and she would be arrested if Plaintiff did not pay this debt. On or about July 1, 2015, Plaintiff answered another call from Defendant and spoke with another representative at ARA. Fearful that she would be arrested, and relying on ARA’s statements and misrepresentations, Plaintiff agreed to make a one-time payment of $2,504.23 to ARA. On or about July 8, 2015, Plaintiff refused a FedEx package from Defendant. On or about July 9, 2015, Defendant called Plaintiff and represented to Plaintiff that Defendant was a lawyer and threaten to sue Plaintiff, which is a violation of the FDCPA and RFDCPA. On or about July 2, 2015, Defendant mailed Plaintiff a letter attempting to collect the alleged debt from First Card, Account No. 4678065218793 for $19,649.90, ARA File #: 1662598-01. This letter is attempting to collect a debt on which the statute of limitations has expired. Nothing in the letter disclosed the date of the transaction giving rise to the claimed debt, or that the debt was barred by the statute of limitations, in violation of the FDCPA and the RFDCPA.
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