12. At all times relevant, Plaintiff was a citizen of the State of Arizona.  Plaintiff  is, and at all times mentioned herein was, a “person” as defined by 47 U.S.C.  § 153 (10).  13. CMRE is, and at all times mentioned herein was, a corporation and a  “person,” as defined by 47 U.S.C. § 153 (10).   14. At all times relevant, CMRE conducted business in the State of Arizona and  in the County of Maricopa, within this judicial district.  15. On or about August 23, 2012 at approximately 12:55 p.m., Defendant  contacted Plaintiff on Plaintiff’s cellular telephone number via an “automatic  telephone dialing system” (“ATDS”), as defined by 47 U.S.C. § 227(a)(1),  using an “artificial or prerecorded voice” as prohibited by 47 U.S.C. § 227(b) 29. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (the “Class”).  30. Plaintiff represents, and is a member of the Class, consisting of: All persons  within the United States who received any telephone call from Defendant or  its agent/s and/or employee/s to said person’s cellular telephone made through  the use of any automatic telephone dialing system or with an artificial or  prerecorded voice, which call was not made for emergency purposes or with  the recipient’s prior express consent, within the four years prior to the filing  of the Complaint.  31. 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 several thousands, if not more. Thus, this matter  should be certified as a Class action to assist in the expeditious litigation of  this matter.  32. Plaintiff and members of the Class were harmed by the acts of Defendant in at  least the following ways: Defendant, either directly or through its agents,  illegally contacted Plaintiff and the Class members via their cellular  telephones by using artificial or prerecorded voice messages, thereby causing  Plaintiff and the Class members to incur certain cellular telephone charges or  reduce cellular telephone time for which Plaintiff and the Class members  previously paid, and invading the privacy of said Plaintiff and the Class  members.  Plaintiff and the Class members were damaged thereby.  41. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.  42. 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.  45. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.  46. 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.  47. 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).  48. Plaintiff and the Class are also entitled to and seek injunctive relief  prohibiting such conduct in the future. KNOWING AND/OR WILLFUL OF THE TELEPHONE CONSUMER PROTECTION ACT (TCPA) 47 U.S.C. 227  NEGLIGENT VIOLATIONS OF THE TELEPHONE CONSUMER PROTECTION ACT (TCPA) 47 U.S.C. 227  THE TCPA, 47 U.S.C. § 227 ET SEQ. • 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)(B). • Pursuant to 47 U.S.C. § 227(b)(3)(A), injunctive relief prohibiting such  conduct in the future. • Any other relief the Court may deem just and proper.