13.  On or around September 6, 2017, Defendant called Plaintiff on his  landline telephone ending 2045 in an attempt to collect a debt.  Defendant called  from the telephone number 800-551-0646.     14.  On or around October 20, 2017, Plaintiff returned Defendant’s call  using his cell phone ending 8165 to call Defendant at 800-551-0646 to inform  Defendant that he was filing bankruptcy.   15.  When Defendant answered the call, it went straight to a live  representative.  There was no pre-recorded warning that the call would be recorded,  and the representative did not verbally provide any warning that the call would be  recorded.   16.  During the call, Defendant asked for the last four digits of Plaintiff’s  social security number which Plaintiff provided.  Defendant indicated there was an  outstanding balance and they discussed Plaintiff’s pending bankruptcy.     17.  At the end of the call, Plaintiff asked if the call was recorded and  Defendant answered affirmatively.   18.  Plaintiff was upset the call was recorded without his consent and ended  the call.  The call lasted about a minute and a half.   19.  At no point during the conversation with Defendant was Plaintiff  advised that the conversation was being recorded by Defendant, nor did Plaintiff  consent to the call being recorded.   37.  Plaintiff brings this action on behalf of himself and on behalf of all other  similar situated (“the CIPA Class”).  Because Plaintiff’s cellular phone calls were  recorded, the representative Plaintiff represents, and is a member of the Class he  seeks to represent, persons whose cellular telephone calls were recorded by  Defendant in the Class Period from one year prior to the filing of this Complaint  through the date of trial, with the Class defined as follows:   Class: All persons from one year prior to the filing of this Complaint  through the date of trial, that engaged in a telephone conversation with  Defendant, their employees, agents or other persons working on  Defendant’s behalf, which was recorded by Defendant, their employees  and agents, while engaging in such communication using a cellular  telephone with a California area code (i.e., 209, 213, 310, 323, 408, 415,  424, 442, 510, 530, 559, 562, 619, 626, 650, 657, 661, 707, 714, 760,  805, 818, 831, 858, 909, 916, 925, 949, or 951).   38.  Defendant, and 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 several thousands, if not more.  Thus, this matter should be  certified as a Class action to assist in the expeditious litigation of this matter.   48.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   COLLECTIONS, INC.,  Defendant.  Case No.:   UNLAWFUL INVASION OF PRIVACY  CALIFORNIA PENAL CODE SECTION 632.7  