14.  In addition to the facts pled above, at various times prior to the  filing of the instant complaint, including within one year preceding the filing of  this complaint, DEFENDANT contacted PLAINTIFF in an attempt to collect an  alleged outstanding debt.     15.  On or about 2014, Plaintiff began receiving numerous calls from  Defendant.     16.  During these telephone calls and recorded in voice messages on  November 6, 2014 and November 14, 2014, Defendant informed Plaintiff that  that she would be served at her place of residence or at her work in relation to a  suit brought against her.   19.  Plaintiff brings this action individually and on behalf of all others  similarly situated, as a member of the proposed class (hereafter “The Class”)  defined as follows:  All persons within the United States who received any  telephone calls from Defendant to said person’s cellular  telephone made through the use of any automatic telephone  dialing system or an artificial or prerecorded voice and  such person had not previously consented to receiving such  calls within the four years prior to the filing of this  Complaint   21.  Plaintiff represents, and is a member of, The Class, consisting of All  persons within the United States who received any collection telephone calls from  Defendant to said person’s cellular telephone made through the use of any  automatic telephone dialing system or an artificial or prerecorded voice and such  person had not previously not provided their cellular telephone number to  Defendant within the four years prior to the filing of this Complaint.   22.  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.   23.  The Class is so numerous that the individual joinder of all of its  members is impractical.  While the exact number and identities of The Class  members are unknown to Plaintiff at this time and can only be ascertained  through appropriate discovery, Plaintiff is informed and believes and thereon  alleges that The Class includes thousands of members.  Plaintiff alleges that The  Class members may be ascertained by the records maintained by Defendant.   9.    Beginning in or around 2014, Defendant contacted Plaintiff on her  cellular telephone number ending in -0402, in an effort to collect an alleged debt  owed from Plaintiff.    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.   Violations of the Fair Debt Collection Practices Act  15 U.S.C. § 1692 et seq.  WHEREFORE, Plaintiff respectfully prays that judgment be entered against  Defendant for the following: 