14. Sometime prior to December 19, 2017, Plaintiff allegedly incurred financial  obligations (the “Debt”) to a creditor.   15. Subsequently the Debt was assigned, placed, or otherwise transferred to  Defendant for collection.   16. Prior to December 19, 2017, Plaintiff obtained representation from Attorney,  Daniel G. Shay (“Mr. Shay”).   17. On or about December 19, 2017, Mr. Shay sent a cease and desist letter to all  of Plaintiff’s creditors by facsimile advising the creditors of Plaintiff’s  representation and demanding them to cease all communications with  Plaintiff.     26. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (“the Class”).   38. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   39. The foregoing acts and omissions of Defendant constitutes multiple negligent  violations of the TCPA, including but not limited to each and every one of  the above-cited provisions of 47 U.S.C. § 227 et seq.   40. As a result of Defendant’s negligent violations of 47 U.S.C. § 227 et seq.,  Plaintiff and the Class are entitled to an award of $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   42. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   43. The foregoing acts and omissions of Defendant constitute multiple knowing  and/or willful violations of the TCPA, including but not limited to each and  every one of the above-cited provisions of 47 U.S.C. § 227 et seq.   44. As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. §  227 et seq., Plaintiff and each member of the Class is entitled to treble  damages, as provided by statute, up to $1,500.00, for each and every  violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. §  227(b)(3)(C).   45. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  FOR KNOWING AND/OR WILLFUL VIOLATION  OF THE TCPA, 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 seeks for herself and each Class member  treble damages, as provided by statute, up to $1,500.00 for each and  every violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. §  227(b)(3)(C).  • Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting  such conduct in the future.  • Any other relief the Court may deem just and proper.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE  TELEPHONE  CONSUMER PROTECTION ACT 47 U.S.C. § 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER  PROTECTION ACT 47 U.S.C. § 227 ET SEQ.  