10.  Defendant also called Plaintiff on June 10, 2015 at 12:25p.m. on her  cellular telephone.   11.   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 the  debt allegedly owed   12.  Defendant’s calls constituted calls that were not for emergency  purposes as defined by 47 U.S.C. § 227(b)(1)(A).   13.  Defendant’s calls were placed to telephone number assigned to a  cellular telephone service for which Plaintiff incurs a charge for incoming calls  pursuant to 47 U.S.C. § 227(b)(1).    14.  Accordingly, Defendant never received Plaintiff’s “prior express  consent” to receive calls using an automatic telephone dialing system or an  artificial or prerecorded voice on her cellular telephone pursuant to 47 U.S.C. §  227(b)(1)(A).    8.    Beginning in and around June of 2015, Defendant contacted Plaintiff  on her cellular telephone ending in -0402 in an attempt to collect an alleged  outstanding debt.   9.  Defendant called Plaintiff from telephone number (800)761-6097 on  June 9, 2015 at 9:29a.m., 1:00p.m., and 6:43p.m.   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 26th day of June, 2015. 