15.  Plaintiff re-states, re-alleges, and incorporates herein by reference, paragraphs one (1)  through fourteen (14) as if set forth fully in this cause of action.   16.  This cause of action is brought on behalf of Plaintiff and the members of a class.   17.  The class consists of all persons whom Defendant’s records reflect resided in New York  who received a communication from Defendant within one year prior to the date of the  within complaint up to the date of the filing of the complaint; and the communication  -4-  was served in a jurisdiction other than a jurisdiction in which the Plaintiff resides, in  violation of 15 U.S.C. §§ 1692e, 1692e(2), 1692e(5), 1692e(10), 1692f, and 1692i(a)(2).   18.  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 communication 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 himself and the  members of a class, as against the Defendant.  