18.  Plaintiff re-states, re-alleges, and incorporates herein by reference, paragraphs one (1)  through seventeen (17) as if set forth fully in this cause of action.   19.  This cause of action is brought on behalf of Plaintiff and the members of a class.   20.  The class consists of all persons whom Defendant's records reflect resided in the State of  New York and who were sent a collection letter bearing the Defendant's letterhead in  substantially the same form as the letter sent to the Plaintiff, sent within one year prior to  the date of the within complaint; (a) the collection letter was sent to a consumer seeking  payment of consumer debts purportedly owed to GE Money Bank; and (b) the collection  letter was not returned by the postal service as undelivered; (c) and the Plaintiff asserts  that the letter contained violations of 15 U.S.C. §§ 1692e, 1692e(5), 1692e(8) and  1692e(10) for making false and deceptive threats of credit reporting and for stating false  credit information.  -4-   21.  Pursuant to Federal Rule of Civil Procedure 23, a class action is appropriate and  preferable in this case because:  (a) Based on the fact that a form collection letter is at the heart of this litigation, the  class is so numerous that joinder of all members is impracticable.   (b) There are questions of law and fact common to the class and these questions  predominate over any question(s) affecting only individual class members.  The  principal question presented by this claim is whether the Defendant violated the  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.  