48.  Plaintiff re-states, re-alleges and incorporates herein by reference, paragraphs one (1)  through one forty-seven (47) as if set forth fully in this cause of action.   49.  This cause of action is brought on behalf of Plaintiff and the members of three classes.   50.  Class A consists of all persons whom Defendant’s records reflect resided in the State of  New York who observed an account that appeared on their credit report(s); (a) wherein  the Defendant had furnishing the national credit bureaus with a statement, that the account  had been assigned to an attorney; and (b) the Defendant violated 15 U.S.C. §§  1692e(2)(A), 1692e(3), 1692e(5), 1692e(8), and 1692e(10) of the FDCPA for the false  representation of the character, amount, or legal status of the debt.   51.  Class B consists of all persons whom Defendant’s records reflect resided in the State of  New York who communicated with Defendant within one year prior to the date of the  within complaint up to the date of the filing of the complaint; (a) the Defendant denied  the Plaintiff the right to dispute the debt by maintaining that the Plaintiff provide a reason  for her dispute; and (b) the Defendant made false statements in violation of 15 U.S.C. §§  1692e(8) and 1692e(10).  -8-   52.  Class C consists of all persons whom Defendant’s records reflect resided in the State of  New York who observed an account that appeared on their credit report(s); (a) wherein  the Defendant had furnishing the national credit bureaus with a statement, that the account  had been assigned to an attorney; and (b) the Defendant violated 15 U.S.C. §§ 1692e(2)(A)  and 1692f(1) for collecting on a debt which was not expressly authorized by the agreement  creating the debt or permitted by law.   53.  Pursuant to Federal Rule of Civil Procedure 23, a class action is appropriate and preferable  in this case because:  A. The class is so numerous that joinder of all members is impracticable, though  the precise number of class members may be known only to the Defendant.  Plaintiff estimates that each class has thousands of members  B. There are questions of law and fact common to the class and these questions  predominate over any questions affecting only individual class members. The  principal question presented by this claim is whether the Defendant violated  the FDCPA.  C. The only individual issue is the identification of the consumers who observed  such language in their credit reports, furnished by the Defendant to the credit  bureaus (i.e. the class members), a matter capable of ministerial determination  from the records of Defendant.  D. The claims of the Plaintiff are typical of those of the class members. All are  based on the same facts and legal theories.  E. The Plaintiff will fairly and adequately represent the class members’ interests.  The Plaintiff has retained counsel experienced in bringing class actions and  -9-  collection-abuse claims. The Plaintiff's interests are consistent with those of  the members of the class.     54.  A class action is superior for the fair and efficient adjudication of the class members’  claims. Congress specifically envisions class actions as a principal means of enforcing the  FDCPA. 15 U.S.C. § 1692(k). The members of the class are generally unsophisticated  individuals, whose rights will not be vindicated in the absence of a class action.  Prosecution of separate actions by individual members of the classes would create the risk  of inconsistent or varying adjudications resulting in the establishment of inconsistent or  varying standards for the parties and would not be in the interest of judicial economy.   55.  If the facts are discovered to be appropriate, the Plaintiff will seek to certify a class  pursuant to Rule 23(b)(3) of the Federal Rules of Civil Procedure.   56.  Collection attempts, such as those made by the Defendant are to be evaluated by the  objective standard of the hypothetical “least sophisticated consumer.”  Violations of the Fair Debt Collection Practices Act   57.  The Defendant’s actions as set forth above in the within complaint violates the Fair Debt  Collection Practices Act.   Violations of the Fair Debt Collection Practices Act brought by Plaintiff on behalf of herself and the  members of a class, as against the Defendant.  