MEMORANDUM ORDER
DEARIE, District Judge.
Plaintiff Arthur Miller brought this action against three defendants, law firms Wolpoff & Abramson, L.L.P. ("W & A") and Upton, Cohen, and Slamowitz ("UCS") and the National Attorney Network ("NAN"), a nonprofit referral network created to coordinate debt collection efforts. Plaintiff claimed that defendants had: (1) sent debt collection letters purporting to be from attorneys without any meaningful attorney...
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