10.  According to its website, Execu|Search has placed 62,000 people in new jobs for  27,000 companies.  As such, it is reasonable that there would be at least 50 members in each  Class.    11.  The group of potential Class members is so numerous as to make it impracticable  to bring them all before the Court, for which reason Mr. Garcia initiates this litigation for all  persons similarly situated pursuant to Rule 23.   12.  Despite the numerical size of the Classes, the identities of Class members can be  ascertained through Execu|Search’s records.   13.  Mr. Garcia and his counsel do not anticipate any difficulties in the management of  this action as a class action.   14.  Mr. Garcia is committed to vigorous prosecution of this action, will adequately  represent the purported Class members in this action, and has retained competent counsel  experienced in class action litigation.   15.  Mr. Garcia is a member of Class 1 and Class 2 and has no interest antagonistic to  or in conflict with other Class members.   17.  Mr. Garcia’s claims or defenses are typical of the claims or defenses of the Class  Members.   18.  Mr. Garcia has the same interests as other Class members in prosecuting his  claims against Execu|Search.   19.  Mr. Garcia and all Class members sustained damages as a result of  Execu|Search’s wrongful conduct.    20.  A class action is superior to other available methods for the fair and efficient  adjudication of this controversy.    21.  Furthermore, due to the expense and burden of individual litigation, it would be  extraordinarily difficult for Class members to redress the wrongs done to them individually.   23.  Mr. Garcia is an experienced information technology (IT) professional with over a  decade of experience in a wide range of technical applications and programming languages.     24.  In and around September 2017, Bryant Vargas, a recruiter at Execu|Search,  contacted Mr. Garcia about an open IT Trainer position at NewYork-Presbyterian Hospital  55.  Plaintiff, on behalf of himself and those similarly situated, hereby realleges and  incorporates each and every allegation contained in paragraphs 1 through 54 with the same force  as though separately alleged herein.   56.  Under 15 U.S.C. § 1681(b)(3)(A), before taking an adverse employment action  against a job applicant based on a consumer report, the employer must provide the applicant with  a copy of their consumer report.   58.  For this violation, Mr. Garcia and the putative Class 1 members are entitled to the  greater of their actual damages or statutory damages up to $1,000.  59.  Plaintiff, on behalf of himself and those similarly situated, hereby realleges and  incorporates each and every allegation contained in paragraphs 1 through 58 with the same force  as though separately alleged herein.   60.  Under 15 U.S.C. § 1681(b)(3)(A), before taking an adverse employment action  against a job applicant based on a consumer report, the employer must provide the applicant with  a description in writing of their rights under the FCRA.   61.  Here, Execu|Search did not provide Mr. Garcia and the putative Class 2 members  with descriptions in writing of their rights under the FCRA prior to taking adverse employment  actions against them, in violation of the FCRA.     9.  While the exact number of Class members is presently unknown, it is estimated  that there are at least 50 Class members in Class 1 and at least 50 Class members in Class 2.     Failure to Provide Copy of Consumer Report in Violation of the FCRA   Failure to Provide Description of Rights in Violation of the FCRA   