10.   Sometime before 2017, Plaintiff is alleged to have incurred certain financial  obligations to Defendant.   11.   Plaintiff allegedly fell behind in the payments allegedly owed on the alleged  debt.     12.   Thereafter, Plaintiff retained the services of the Law Office of Daniel G. Shay  (“DGS”) to assist Plaintiff with resolving Plaintiff’s alleged debt.   13.   In this regard, DGS transmitted a Letter of Representation (“LOR”) to  Defendant via U.S. Mail and facsimile on August 29, 2017.   14.   Said LOR indicated that Defendant was to cease all communications with  Plaintiff.    15.   Said LOR informed Defendant that Plaintiff was a represented party with  regard to Plaintiff’s alleged debt and provided Defendant with DGS’s name  and contact information.   16.   The LOR also demanded all future communications with regard to Plaintiffs’  account be sent and directed directly to DGS’s office only.   32.    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  phone calls from Defendant or Defendant’s agent/s  and/or employee/s to said person’s cellular telephone  made through the use of any automatic telephone dialing  system within the four years prior to the filing of this  Complaint without prior express consent.   33.    Plaintiff represents, and is a member of, The Class, consisting of All persons  within the United States who received any calls from Defendant or  Defendant’s agent/s and/or employee/s to said person’s cellular telephone  made through the use of any automatic telephone dialing system within the  four years prior to the filing of this Complaint.   34.    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.   47.   Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   48.   The foregoing acts and omissions of Defendant constitutes numerous and  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.   49.   As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. §  227 et seq., Plaintiff is entitled to an award of $1,500.00 in statutory damages,  for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B) and 47  U.S.C. § 227(b)(3)(C).   50.   Plaintiff is also entitled to and seek injunctive relief prohibiting such conduct  in the future.  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.  