48.  Plaintiff re-states, re-alleges, and incorporates herein by reference, paragraphs one (1)  through 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 two classes.   50.  Class A consists of all persons whom Defendant's records reflect resided in the State of  New York (a) whom the Defendant’s records reflect that it attempted to collect  delinquent medical debts from Medicaid recipients when it was aware of the debtors  Medicaid eligibility in violation of both Federal and New York State law; and (b) the  Defendant was aware that the said account was already in disputed-status; and (c) the  Defendant threatened to communicate, credit information which the Defendant knew to  be false; (d) the Plaintiff asserts that the Defendant violated 15 U.S.C. §§ 1692e,  1692e(2)(A), 1692e(5), 1692e(8), 1692e(10), 1692f and 1692f(1).   51.  Class B consists of all persons whom Defendant's records reflect resided in the State of  New York and who were sent a collection letter in substantially the same form letter as  the letter sent to the Plaintiff on or about September 4, 2015; and (a) the collection letter  was sent to a consumer seeking payment of a personal debt purportedly owed to Sullivan  Emergency Services; 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. §§ 1692, 1692e, 1692e(2)(a), 1692e(5), 1692e(10), and 1692f, for doing business  when its authority to do so in New York had been suspended.   52.  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 are 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 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 were  sent such collection letters (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 collection-abuse claims. The Plaintiff's interests are consistent  with those of the members of the class.     53.  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.       54.  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.   55.  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   56.  The Defendant's actions as set forth above in the within complaint violates the Fair Debt  Collection Practices Act.   57.  Because the Defendant violated the Fair Debt Collection Practices Act, the Plaintiff and  the members of the class are entitled to damages in accordance with the Fair Debt  Collection Practices Act.  58.  Plaintiff re-states, re-alleges, and incorporates herein by reference, paragraphs one (1)  through forty seven (47) as if set forth fully in this cause of action.   59.  The conduct of Defendant in collecting and attempting to collect monies owed when it  was not allowed to pursuant to the New York Limited Liability Law constitutes  deceptive or materially misleading activity that is directed at consumers and the public  at large and caused consumers to suffer financial injuries of having increased debt and  having money extracted from them.   60.  As a result of the unlawful collection activity which the Defendant engaged in, Plaintiff  is entitled to damages pursuant to GBL § 349 of $6,388.94 which is actual damages.  WHEREFORE, Plaintiff, respectfully requests preliminary and permanent injunctive relief, and that  this Court enter judgment in her favor and against the Defendant and award damages as follows:      A. Statutory damages provided under the FDCPA, 15 U.S.C. § 1692(k) and  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.   Violations of GBL 349 brought by Plaintiff on behalf of herself and the members of a class, as  against the Defendant.  