10.   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  by “Breanna Grace.”   11.  Defendant’s calls constituted calls that were not for emergency purposes as  defined by 47 U.S.C. § 227(b)(1)(A).   12.  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.  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 collection  telephone calls from Defendant to said person’s cellular  telephone made through the use of any automatic telephone  dialing system and such person had not previously consented to  receiving such calls within the four years prior to the filing of this  Complaint   15.  Plaintiff represents, and is a member of, The Class, consisting of All persons  within the United States who received any collection telephone call from Defendant to said  person’s cellular telephone made through the use of any automatic telephone dialing system  and such person had not previously not provided their cellular telephone number to Defendant  within the four years prior to the filing of this Complaint.   16.  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.   17.  The Class is so numerous that the individual joinder of all of its members is  impractical.  While the exact number and identities of The Class members are unknown to  Plaintiff at this time and can only be ascertained through appropriate discovery, Plaintiff is  informed and believes and thereon alleges that The Class includes thousands of members.   Plaintiff alleges that The Class members may be ascertained by the records maintained by  Defendant.   8.    Beginning in or around July of 2012, Defendant contacted Plaintiff on her  cellular telephone, (909) 684-4164, in an attempt to collect an alleged outstanding debt owed  by someone other than Plaintiff.   9.   Defendant placed multiple calls, often on a virtual daily basis to Plaintiff’s  cellular telephone seeking to collect the alleged debt owed by an unknown debtor who is not  Plaintiff.   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 18th Day of October, 2012. 