12.  Beginning in or around June of 2017, Defendant contacted Plaintiff  on her cellular telephone number ending in -3644, in an effort to collect an alleged  debt owed from Plaintiff.    13.  Defendant called Plaintiff from telephone numbers confirmed to  belong to Defendant, including without limitation (760) 630-4665.   14.  In its efforts to collect the alleged debt owed from Plaintiff, 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 an alleged debt owed.   15.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   21.  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.     22.  On or about November of 2016 through September of 2017, Plaintiff  began receiving numerous letters from Defendant, in an attempt to collect upon an  alleged debt.    23.  On or about June through September of 2017, Plaintiff began  receiving numerous calls from Defendant.     29.  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   30.  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.   40.  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 residing in the United States, who, within the  one (1) year preceding the filing of this Complaint,  received collection correspondence, through the use of  the United States Postal Service, from Defendant that  attempted to charge interest, fees, or charges not  authorized in the original agreement or by state law   41.  Plaintiff represents, and is a member of, The Class, consisting of All  persons residing in the United States, who, within the one (1) year preceding the  filing of this Complaint, received collection correspondence, through the use of the  United States Postal Service, from Defendant that attempted to charge interest, fees,  or charges not authorized in the original agreement or by state law.   42.  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.   43.  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.   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.   Negligent Violations of the Telephone Consumer Protection Act  47 U.S.C. §227 et seq.   As a result of Defendant’s negligent violations of 47 U.S.C.  §227(b)(1), Plaintiff and the Class members are entitled to and  request $500 in statutory damages, for each and every violation,  pursuant to 47 U.S.C.  227(b)(3)(B).    Any and all other relief that the Court deems just and proper.  