19.         Plaintiff brings this action on behalf of herself and all others similarly  situated, as a member of the proposed class (hereafter “The Class”) defined as  follows:  All persons in the United States whose bank accounts  were debited on a reoccurring basis by Defendant  without Defendant obtaining a written authorization  signed or similarly authenticated for preauthorized  electronic fund transfers within the one year prior to the  filing of this Complaint.   20.  Plaintiff represents, is a member of, The Class, consisting of all  persons within the United States whose bank account was debited on a recurring  basis by Defendant without Defendant obtaining a written authorization signed or  similarly authenticated for preauthorized electronic fund transfers within the one  year prior to the filing of this Complaint.   21.  Defendant, its employees and agents are excluded from The Class.   Plaintiff does not know the number of members in The Class, but believes the  Class members number in the thousands, if not more.  Thus, this matter should be  certified as a Class Action to assist in the expeditious litigation of the matter.   Violations of the Electronic Funds Transfer Act  15 U.SC. §1693 et seq.  