10.   Defendant used an “automatic telephone dialing system”, as defined by 47  U.S.C. § 227(a)(1) to place its calls to Plaintiff seeking to collect the debt allegedly owed by  “Jabaree Walker.”   15.  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 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 consented to receiving such calls  within the four years prior to the filing of this Complaint   16.  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.   8.    Beginning in or around November 2012, Defendant contacted Plaintiff on her  cellular telephone, (714) 271-3426, in an attempt to collect an alleged outstanding debt owed  by a “Jabaree Williams.”   9.   To date, Defendant has placed no less than five (5) collection calls to Plaintiff’s  cellular telephone seeking to collect the alleged debt owed by “Jabaree Williams.”   Specifically, Defendant called Plaintiff on November 13, 2012, November 16, 2012, November  20, 2012, November 28, 2012 and November 30, 2012.   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 3rd Day of December, 2012. 