Since the nature and legal status of a debt may be materially affected by bankruptcy proceedings, debt collectors must beware. Liability under the FDCPA may result from a false statement that a borrower's debt is ineligible for bankruptcy. (See Easterling v Collecto, Inc., 692 F3d at 233-235; Gabriele v American Home Mtge. Servicing, Inc.) FDCPA liability may also result from a demand for payment of a debt while the borrower is in bankruptcy or after the debt's discharge in bankruptcy. (See Randolph v IMBS, Inc., 368 F3d 726, 728 [7th Cir 2004]; Turner v J.V.D.B. & Assoc., Inc., 330 F3d 991, 995 [7th Cir 2003].) As Judge Easterbrook explained in Randolph: "A demand for immediate payment while a debtor is in bankruptcy (or after the debt's discharge) is 'false' in the sense that it asserts that money is due, although, because of the automatic stay (11 U.S.C. § 362) or the discharge injunction (11 U.S.C. § 524), it is not." (Randolph v IMBS, Inc., 368 F3d at 728.){**76 Misc 3d at 740} Critically, such misrepresentations are "presumptively wrongful under the [FDCPA]" even if the debt collector is unaware of the borrower's bankruptcy, for ignorance is no excuse. (See Randolph v IMBS, Inc. at 728; Turner v J.V.D.B. & Assoc., Inc., citing Russell v Equifax A.R.S., 74 F3d 30, 33 [2d Cir 1996].) Since the FDCPA is a strict liability statute, "there is no need for a plaintiff to plead or prove that a debt collector's misrepresentation of a debt obligation was intentional." (Vangorden v Second Round, Ltd. Partnership, 897 F3d 433, 438 [2d Cir 2018], supra; see Russell v Equifax A.R.S. [same].)