11.  Neither the scripted nor the pre-recorded message identifies the name of the debt  collection company, that the call was an attempt to collect a debt, that any information obtained  will be used for that purpose, or that the communication was from a debt collector.   12.  PLAINTIFF is informed and believes and therefore alleges that PLAINTIFF and  the class members are entitled to statutory damages and may have also suffered damages in other  ways and to other extents not presently known to PLAINTIFF, and not specified herein.   PLAINTIFF reserves the right to assert additional facts and damages not referenced herein,  and/or to present evidence of the same at the time of trial.  13.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 12 inclusive, above.   15.  A class action is superior for the fair and efficient adjudication of the class  members’ claims as Congress specifically envisioned class actions as a principal means of  enforcing the FDCPA. See 15 U.S.C.§ 1692k.  The members of the class are generally  unsophisticated consumers, whose rights will not be vindicated in the absence of a class action.  Prosecution of separate actions by individual members of the classes would also create the risk  of inconsistent or varying adjudications resulting in the establishment of inconsistent or varying  standards and would not be in the best interest of judicial economy.    16.  If facts are discovered to be appropriate, PLAINTIFF will seek to certify the class  under Rule 23(b)(3) of the Federal Rules of Civil Procedure.  17.  PLAINTIFF repeats, re-alleges and incorporates by reference, paragraphs 1  through 16 inclusive, above.   19.  Further, a debt collector is prohibited from placing “telephone calls without  meaningful disclosure of the caller’s identity”. 15 U.S.C. § 1692d(6).   20.  In July of 2014, DEFENDANT began placing calls to PLAINTIFF’S phone  number in connection with the collection of a consumer debt.  DEFENDANT left the following  scripted and pre-recorded messages, respectively, on PLAINTIFF’S cell phone:  This message is intended for Rochelle Beaulieu, claim number 501- 5975.  If this is not Rochelle disregard this message or contact us so we  can update our records. This is Mike Carol calling in regards to a file  that was submitted into my office. I need to verify information so you  have the opportunity to address the claim and or claims against you.  At  this point you're required to contact our firm to discuss a voluntary  resolution to this matter. We can be reached at 855-893-7266. Claim  number on your file is 501-5975.  This message. This message is solely intended for <Rochelle Beaulieu>.   If you are not <Rochelle Beaulieu>, please hang up now and disregard  this message. We are handling a claim in our office. We are making  every effort to reach you in order to resolve this matter voluntarily and  at this time we are waiting to hear from you. Press 0 to speak with your  representative or call us now at 855-847-8504. The file number is <501- 5975>. Please contact our firm immediately to prevent a default status  on this claim. Again press 0 now or you may be subjected to a default  status within our firm.    21.  DEFENDANT’s scripted and pre-recorded messages fail to identify the name of  the debt collector in an attempt to trick the consumer into calling DEFENDANT back.   22.  Further, DEFENDANT’s scripted and pre-recorded messages fail to identify that  the call was an attempt to collect a debt and that any information obtained will be used for that  purpose, or that the communication was from a debt collector.   24.  It has been necessary for PLAINTIFF to obtain the services of an attorney to  pursue this claim, on behalf of herself and those similarly situated, and is entitled to recover  reasonable attorneys’ fees therefor.  9.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 8 inclusive, above.    VIOLATIONS OF THE FDCPA 15 U.S.C. §§ 1692d(6) and e(2), e(11)   BROUGHT BY PLAINTIFF INDIVIDUALLY AND ON BEHALF OF THE  CLASS   