14. Sometime prior to December of 2016, Plaintiff allegedly incurred a debt to  Bank of America, which was later sold, transferred or assigned to Defendant.   As it is irrelevant to this action, Plaintiff currently takes no position as to  whether or not this alleged debt was actually owed.    15. Plaintiff was one of thousands of consumers harassed by Defendant to pay an  alleged debt.    16. On December 16, 2016, the Law Office of Daniel Shay (“Shay”) with  Plaintiff’s authorization and on Plaintiff’s behalf, faxed and mailed cease and  desist letters to Bank of America informing it and by proxy Defendant of the  following:    [Plaintiff] hereby revokes any prior express consent  that may have been given to receive telephone calls,  expressively to [Plaintiff’s] cellular telephone, from an  Automated Telephone Dialing System or an artificial  or pre-recorded voice, as outlined in the Telephone  Consumer Protection Act, 47 U.S.C. § 227 et seq. and  [Plaintiff] also revokes any applicable business  relationship.  [Plaintiff] has retained [Shay] to stop creditor  harassment and to discharge your claim(s) through  bankruptcy. Whether you are an original creditor, or a  collector, you must cease and desist all communication  with [Plaintiff] as required by Cal. Civ. Code §  1788.17 via 15 U.S.C. 1692…   34. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (the “Class”).   46. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   47. The foregoing acts and omissions of Defendant constitute numerous and  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.   48. 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).   50. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   51. The foregoing acts and omissions of Defendant constitute 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.   52. As a result of Defendant’s knowing and/or willful violations of 47 U.S.C. §  227, et seq., Plaintiff and the Class are 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).   53. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  KNOWING AND/OR WILLFUL VIOLATIONS OF THE TCPA  47 U.S.C. § 227 ET SEQ.   NEGLIGENT VIOLATIONS OF THE TCPA  47 U.S.C. § 227 ET SEQ.  