10.  Defendant’s calls were placed to telephone number assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    11.  Accordingly, Defendant never received Plaintiff’s “prior express  consent” to receive calls using an automatic telephone dialing system or an artificial  or prerecorded voice on her cellular telephone pursuant to 47 U.S.C. § 227(b)(1)(A).     12.   In November 2015, Plaintiff requested that Defendant stop calling her,  as she was going through bankruptcy proceedings. Defendant continued to call  Plaintiff on multiple occasions after November 2015, and continued to leave  messages on Plaintiff’s cellular phone.  6.    Beginning in and around December 2014, Defendant contacted  Plaintiff on her cellular telephone, ending in -1469, in an attempt to collect an  alleged outstanding debt.   7.  Defendant often left voicemail messages on Plaintiff’s cellular  telephone if Plaintiff did not answer Defendant’s calls.  In these messages,  Defendant utilized an “artificial or prerecorded voice” as prohibited by 47 U.S.C.  § 227(b)(1)(A).   8.   Defendant used an “automatic telephone dialing system”, as defined  by 47 U.S.C. § 227(a)(1) to place its daily calls to Plaintiff seeking to collect the  debt allegedly owed   9.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   Knowing and/or Willful Violations of the Telephone Consumer Protection  Act   47 U.S.C. §227 et seq.  • As a result of Defendant’s willful and/or knowing violations of 47  U.S.C. §227(b)(1), Plaintiff and the Class members are entitled to   and request treble damages, as provided by statute, up to $1,500, for  each and every violation, pursuant to 47 U.S.C. §227(b)(3)(B) and 47  U.S.C. §227(b)(3)(C).   • Any and all other relief that the Court deems just and proper.   Respectfully Submitted this 26th day of January, 2016. 