29. Plaintiff brings suit on behalf of herself and on behalf of all other participants  and beneficiaries similarly situated under the provisions of Rule 23 of the Federal Rules of  Civil Procedure with respect to violations alleged herein.  30. The proposed Class is defined as follows: All persons who participated in the Allmerica Cash Balance Pension Plan who vested  or will vest in an accrued benefit under the Plan’s cash balance formula between  January 1, 1995 and December 31, 2004; and the beneficiaries and estates of such  persons.  31. The requirements for maintaining this action as a class action under Fed. R.  Civ. P. 23(a)(1) are satisfied in that there are too many Class members for joinder of all of  8 them to be practicable.  There are thousands of members of the proposed Class dispersed  among many states.   32. The claims of the Class members raise numerous common questions of fact  and law, thereby satisfying the requirements of Fed. R. Civ. P. 23(a)(2).  All issues  concerning liability are common to all Class members because such issues concern their  entitlement to benefits calculated in a manner other than that calculated thus far and their  entitlement to relief from harm caused by the violations of law, rather than any action taken  by Plaintiffs or any Class member.  In addition, all issues concerning relief are also common  to the Class.    33. The computation of a participant’s lump sum distribution and the amount of  lump sum distributions is standardized in that the amount of the lump sum distribution for  each member of the Class was calculated in the same manner as described above.  Thus, there  exist common questions of fact as to each member of the Class.  Each Class member’s rights  will be determined by resort to the same Plan documents and the same provisions of ERISA.   Thus, there exist common questions of law as to each Class member, i.e., whether the method  of calculating of lump sum distributions violated the law.   34. Plaintiff’s claims are typical of the claims of Class members, and therefore  satisfy the requirements of Fed. R. Civ. P. 23(a)(3).  She does not assert any claims relating to  the Plan in addition to or different than those of the Class.  Plaintiff’s claims are typical of the  claims of the Class members in that her lump sum distribution was calculated in the same  fashion as the rest of the Class, and her rights as well as those of the Class as a whole, are  similarly provided for under the plan document and applicable provisions of ERISA.  9  35. Plaintiff is an adequate representative of the proposed Class, and therefore  satisfies the requirements of Fed. R. Civ. P. 23(a)(4).  Plaintiff’s interests are identical to  those of the proposed Class.  The Plan has no unique defenses against him that would  interfere with their representation of the class.  Plaintiff has engaged counsel with extensive  ERISA class action litigation experience and expertise.   36. Additionally, all of the requirements of Fed. R. Civ. P. 23(b)(1) are satisfied in  that the prosecution of separate actions by individual members of the class would create a risk  of inconsistent or varying adjudications establishing incompatible standards of conduct for  defendants and individual adjudications present a risk of adjudications which, as a practical  matter, would be dispositive of the interests of other members who are not parties.   37. All of the requirements of Fed. R. Civ. P. 23(b)(2) also are satisfied in that the  Plan’s actions affected all Class members in the same manner making appropriate final  declaratory and injunctive relief with respect to the Class as a whole. 