10.  Defendant made the Call to Plaintiff to sell its lending services.   11.  Defendant made the Call using an autodialer.   12.  Defendant made the Call using an artificial or pre-recorded voice.   13.  Plaintiff has never given Defendant express consent to allow Defendant to call  Plaintiff on his cellular telephone.   14.  Prior to the Call, Plaintiff had never heard of Defendant.   15.  Plaintiff has never done business with Defendant.  3   16.  Plaintiff brings this action individually and on behalf of the following putative  Class:  All persons within the United States to whom one or more telephone calls  were made, since April 18, 2012, by, on behalf, or for the benefit of Capital  Advance Solutions, LLC (“Defendant”), which calls were made using an  automatic telephone dialing system and/or an artificial or prerecorded  voice, and for which (a) the called telephone numbers appear in  Defendant’s records of such calls and/or the records of Defendant’s third  party telephone carriers or the third party telephone carriers of Defendant’s  call centers or (b) for which the called persons’ own records prove that they  received such calls.   17.  The Class is so numerous that joinder of all individual members in one action would  be impracticable, given the expected Class size and modest value of individual claims.  On  information and belief, there are more than 100 persons meeting the above-referenced Class  definition.  Class members can be identified through Defendant’s records.   18.  Plaintiff’s claims are typical of the claims of the Class members, as they are based  on the same legal theory and arise from the same unlawful and willful conduct.   19.  There are common questions of law and fact affecting members of the Class, which  common questions predominate over questions that may affect individual members.  These  common questions include, but are not limited to:  a.  Whether Defendant made non-emergency telephone calls to Class  members’ cellular telephones using an autodialer and/or artificial or  prerecorded voice;  b.  Whether Defendant had express consent of Class members to receive such  calls;  c.  Whether Defendant acted knowingly or willfully; and  d.  Whether Defendant should be enjoined from making non-emergency  telephone calls to cellular telephones using an autodialer and/or artificial or  prerecorded voice.  4   20.  Plaintiff will fairly and adequately represent the Class members.  Plaintiff has no  interests that conflict with the interests of Class members.  Plaintiff has retained counsel  experienced in handling consumer class actions.  Neither Plaintiff nor his counsel has any interests  that might cause them not to pursue these claims vigorously.   21.  This action should be maintained as a class action because the prosecution of  separate actions by individual Class members would create a risk of inconsistent or varying  adjudications with respect to individual members that would establish incompatible standards of  conduct for the parties opposing the Class.   22.  Whether Defendant failed to comply with 15 U.S.C. § 1681c(g) can be easily  determined by a review of its policies and records.   23.  A class action is a superior method for the fair and efficient adjudication of this  controversy, particularly given the modest size of claims.  Management of the Class claims is  likely to present significantly fewer difficulties than those presented in many individual claims.   24.  Defendant made the Call to Plaintiff and similar calls to Class members knowing  that it was using an autodialer.   25.  Defendant made the Call to Plaintiff and similar calls to Class members knowing  that it was using an artificial or prerecorded voice.   26.  Defendant was aware, prior to making the Call to Plaintiff and similar calls to Class  members, that it was prohibited by the TCPA from calling Plaintiff’s and Class members’ cellular  telephones using an autodialer and/or artificial or prerecorded voice.   27.  Defendant knowingly and willfully violated the TCPA.   28.  Pursuant to 47 U.S.C. §227(b)(3)(B), Plaintiff and each Class member is entitled to  statutory damages of $500 for each of Defendant’s illegal calls.  5   29.  Pursuant to 47 U.S.C. §227(b)(3), Plaintiff and each Class member is entitled to  treble damages of up to $1,500 for each of Defendant’s illegal calls.  WHEREFORE, Plaintiff, individually and on behalf of the putative Class, requests that this  Court enter judgment in his favor and against Capital Advance Solutions, LLC and award the  following:  a.  Statutory damages pursuant to 47 U.S.C. § 227(b)(3)(B);  b.  Treble damages pursuant to 47 U.S.C. § 227(b)(3)(B);  c.  Costs;  d.  An injunction enjoining Defendant from making calls that violate the TCPA  in the future; and  e.  Such further relief as this Court deems just and proper.  Plaintiff Demands a Trial By Jury  SCOTT D.H. REDMAN, Plaintiff,  By:  s/ Paul F. Markoff  One of Plaintiff’s Attorneys  Paul F. Markoff (IL Atty. No. 6237614)  Karl G. Leinberger (IL Atty. No. 6237537)  Markoff Leinberger LLC  134 N LaSalle St, Ste 1050  Chicago IL 60602  312.726.4162 (p)  312.674.7272 (f)  paul@markleinlaw.com   8.  Plaintiff incorporates herein by references paragraphs 1-7.   9.  On April 15, 2016, at 2:28 pm (central), Defendant, or its authorized agent, called  Plaintiff on his cellular telephone (the “Call”), at the number xxx.xxx.4666.   Violation of the TCPA  