10.  At all times relevant, Plaintiff was a citizen of the State of California.   Plaintiff is, and at all times mentioned herein was, a “person” as defined by 47  28.  Plaintiff brings this action on behalf of herself and on behalf of and  all others similarly situated (“the Class”).   29.  Plaintiff represents, and is a member of, the Class, consisting of All  persons within the United States who received any telephone calls from  Defendant to said person’s cellular telephone made through the use of any  automatic telephone dialing system or an artificial or prerecorded voice and such  person had not previously consented to receiving such calls within the four years  prior to the filing of this Complaint   30.  Defendant and its employees or 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 this matter.   40.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   41.  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.   42.  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).   43.  Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future.  44.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   45.  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.   48.  As a result of Defendant’s negligent violations of 47 U.S.C. §  227(b)(1), Plaintiff seeks for himself and each Class member $500.00 in statutory  damages, for each and every violation, pursuant to 47 U.S.C. § 227(b)(3)(B).   49.  Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting  such conduct in the future.   50.  Any other relief the Court may deem just and proper.  51.  As a result of Defendant’s knowing and/or willful violations of 47  U.S.C. § 227(b)(1), Plaintiff seeks for himself and each Class member $1,500.00  in statutory damages, for each and every violation, pursuant to 47 U.S.C. §  227(b)(3)(C).   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.   TCPA, 47 U.S.C. § 227 ET SEQ.   VIOLATIONS OF THE TCPA, 47 U.S.C. § 227 ET SEQ.  