17.  Shortly after Plaintiff obtained a new cellular telephone number— (251) 301-XXXX—Defendant began placing calls to it.   18.  In an attempt to contact a third party unknown to Plaintiff for the  purpose of attempting to collect a debt in default, Defendant placed numerous calls  to cellular telephone number (251) 301-XXXX—a number for which Plaintiff is  the subscriber and customary user.   20.  Upon information and good faith belief, Defendant’s records will  show additional calls that it made to Plaintiff’s cellular telephone number with an  automatic telephone dialing system or an artificial or prerecorded voice.   21.  Defendant placed its calls to Plaintiff’s cellular telephone number  from (603) 570-4414—a telephone number assigned to Defendant.   22.  Defendant placed all of the above-referenced calls in an effort to  contact and collect a debt allegedly owed by a third party named “Deborah,” who  was unknown to Plaintiff.   23.  On at least one occasion, Plaintiff answered a call from Defendant on  her cellular telephone and, after a delay, was greeted by a representative asking to  speak with someone named “Deborah.”   24.  During the call, Plaintiff told the representative that Defendant was  calling the wrong number, and requested that Defendant stop calling her cellular  telephone.   25.  Upon information and good faith belief, and in light of the frequency,  number, nature, and character of the calls, Defendant placed its calls to Plaintiff’s  cellular telephone number by using an automatic telephone dialing system.   28.  Plaintiff does not have, nor had, any business relationship with  Defendant.   29.  Plaintiff did not provide Defendant with her cellular telephone  number.   30.  Plaintiff did not give Defendant prior express consent to place calls to  her cellular telephone number by using an automatic telephone dialing system.   31.  Upon information and good faith belief, Defendant placed its calls to  Plaintiff’s cellular telephone number for non-emergency purposes.   32.  Upon information and good faith belief, Defendant placed its calls to  Plaintiff’s cellular telephone number voluntarily.   33.  Upon information and good faith belief, Defendant placed its calls to  Plaintiff’s cellular telephone number under its own free will.   34.  Upon information and good faith belief, Defendant had knowledge  that it was using an automatic telephone dialing system to place calls to Plaintiff’s  cellular telephone number.   36.  Upon information and good faith belief, Defendant maintains business  records that show all calls it placed to Plaintiff’s cellular telephone number.   37.  Plaintiff suffered actual harm as a result Defendant’s calls in that she  suffered an invasion of privacy, an intrusion into her life, and a private nuisance.   38.  As well, Defendant’s calls at issue depleted or consumed, directly or  indirectly, cellular telephone minutes for which Plaintiff paid a third party.   39.  Moreover, Defendant’s calls at issue unnecessarily tied up Plaintiff’s  cellular telephone line.   40.  Upon information and good faith belief, Defendant, as a matter of  pattern and practice, uses an automatic telephone dialing system to place calls to  telephone numbers assigned to a cellular telephone service.  42.  Excluded from the classes is Defendant, its officers and directors,  members of their immediate families and their legal representatives, heirs,  successors, or assigns, and any entity in which Defendant has or had controlling  interests.   43.  The proposed classes satisfy Rule 23(a)(1) because, upon information  and belief, they are so numerous that joinder of all members is impracticable.    44.  The exact number of class members is unknown to Plaintiff at this  time and can only be ascertained through appropriate discovery.   45.  The members of the classes are ascertainable because the classes are  defined by reference to objective criteria.     47.  There exists a well-defined community of interest in the questions of  law and fact that affect the members of the classes.   48.  Plaintiff’s claims are typical of the claims of the members of the  classes.   49.  As it did for all members of the classes, Defendant used an automatic  telephone dialing system to place calls to Plaintiff’s cellular telephone number,  without prior express consent, and in violation of 47 U.S.C. § 227.   50.  Further, like all members of the proposed Debt Collection Class,  Plaintiff received telephone calls from Defendant in connection with the collection  of a consumer debt that she did not owe.   51.  Plaintiff’s claims, and the claims of the members of the classes,  originate from the same conduct, practice, and procedure on the part of Defendant.   52.  Plaintiff’s claims are based on the same theory as are the claims of the  members of the classes.   53.  Plaintiff suffered the same injuries as each of the members of the  classes.   54.  Plaintiff will fairly and adequately protect the interests of the  members of the classes.   56.  Plaintiff will vigorously pursue the claims of the members of the  classes.   57.  Plaintiff has retained counsel experienced and competent in class  action litigation.   58.  Plaintiff’s counsel will vigorously pursue this matter.   59.  Plaintiff’s counsel will assert, protect, and otherwise represent the  members of the classes.   60.  Questions of law and fact common to the members of the classes  predominate over questions that may affect individual class members.   62.  A class action is superior to all other available methods for the fair  and efficient adjudication of this matter.   63.  If brought and prosecuted individually, the claims of the members of  the classes would require proof of the same material and substantive facts.   64.  The pursuit of separate actions by individual members of the classes  would, as a practical matter, be dispositive of the interests of other members of the  classes, and could substantially impair or impede their ability to protect their  interests.   65.  The pursuit of separate actions by individual members of the classes  could create a risk of inconsistent or varying adjudications, which might establish  incompatible standards of conduct for Defendant.   66.  These varying adjudications and incompatible standards of conduct, in  connection with presentation of the same essential facts, proof, and legal theories,  could also create and allow the existence of inconsistent and incompatible rights  within the classes.   68.  The pursuit of Plaintiff’s claims, and the claims of the members of the  classes, in one forum will achieve efficiency and promote judicial economy.   69.  There will be little difficulty in the management of this action as a  class action.   70.  Defendant has acted or refused to act on grounds generally applicable  to the members of the classes, making final declaratory or injunctive relief  appropriate.  Count I  Violation of 47 U.S.C. § 227(b)(1)(A)(iii)   71.  Plaintiff repeats and re-alleges each and every factual allegation  included in paragraphs 1 through 70.   72.  Defendant violated 47 U.S.C. § 227(b)(1)(A)(iii) by using an  automatic telephone dialing system or an artificial or prerecorded voice to make  and/or place non-emergency calls to Plaintiff’s cellular telephone number, absent  prior express consent.   74.  Plaintiff repeats and re-alleges each and every factual allegation  included in paragraphs 1 through 70.   75.  Defendant violated 15 U.S.C. § 1692d by engaging in conduct the  natural consequence of which is to harass, oppress, or abuse Plaintiff in connection  with the collection of consumer debts.  