15.  Plaintiff allegedly incurred a debt to Defendant’s predecessor in interest,  “Navient” for an educational loan (the “Debt” or “debt”).   16.  She was was thereafter plagued by Navient’s calls for years  commencing sometime between 2014 and 2017 to present.    17.  The debt allegedly originated in or about October 2004.   18.  In 2010, Plaintiff ceased making payments on the alleged debt.     20.  However, in or about 2014 and as late at 2017, Navient begain placing  numerous calls to her cell phone and informed her she owed payments on the debt.     21.  During this time, Plaintiff repeatedly requested Navient cease  contacting her by telling Navient’s representatives to “stop calling” her cell phone.   22.  Indeed, Navient’s collection calls continued several months prior to  filing the instant suit resulting in a separate lawsuit brought against Navient for its  illegal debt collection conduct in this same court.2   23.  At some point within the last year, Navient transferred, sold, assigned or  otherwise conveyed the Debt to WWR for collection.   24.  Thereafter, WWR engaged in placing numerous pre-recorded calls  using an artificial or prerecorded voice to collect the debt from the Plaintiniff even  though Plaintiff already demanded that such communications cease thereby revoking  concent to receive such communications on numerous prior instances.   25.  Indeed, within the several weeks prior to filing the instant complaint (let  alone statutory four year prior under the TCPA), Plaintiff received numerous calls  from WWR from the following phone number: (800)-837-0603.   27.  The calls dialed and complained of here were made using an artificial or  prerecorded voice without prior express consent to place such calls to Plaintiff’s cell  phone.   28.  However, Defendant placed artificial or prerecorded voice calls to  Plaintiff’s cellular telephone without consent in violation of the TCPA even after she  advised WWR to cease calling her cell phone.  Indeed, Defendant’s illegal artificial  or prerecorded voice calls have continued until days before filing this complaint.   29.  The telephone number Defendant used to contact Plaintiff was and is  assigned to a cellular telephone service as specified in 47 U.S.C. § 227(b)(1)(A)(iii).   30.  Defendant’s calls to Plaintiff’s cellular telephone were not for  “emergency purposes.”   31.  Plaintiff suffered actual harm and loss, since each of the unwanted calls  depleted Plaintiff’s cell phone’s battery, and the cost of electricity to recharge the  phone is a tangible harm.  While small, this cost is a real one, and the cumulative  effect can be consequential, just as is true for exposure to X-rays resulting from  Defendant’s unwanted phone calls to Plaintiff’s cell phone.   33.  Plaintiff has a common law right to privacy.  E.g., Samuel D. Warren &  Louis D. Brandeis, The Right to Privacy, 4 Harv. L. Rev. 1155, 193 (1890).   Congress sought to further protect that right by enacting the TCPA.    34.  “[W]hen a person must endure the bother of unwanted calls in the  privacy of her home, her harm is similar to other traditional injuries that courts have  long recognized, such as invasion of privacy and nuisance.”  Toldi v. Hyundai  Capital Am., No. 2:16-CV—01877-APG-GWF, 2017 WL 736882, at *2 (D. Nev.  Feb. 23, 2017).      35.  Plaintiff was also personally affected, since Plaintiff felt Plaintiff’s  privacy had been invaded when Defendant placed calls to Plaintiff’s phone line  without any consent to do so.   36.  The injury suffered by Plaintiff is concrete because Defendant’s  violations caused Plaintiff to suffer an invasion of privacy.  38.  Plaintiff proposes to represent the following Class consisting of and  defined as follows:  All persons within the United States who received any  telephone call(s) from Defendant or its agent(s) and/or  employee(s), not for an emergency purpose, on said person’s  cellular telephone, made through the use of an artificial or  prerecorded voice within the four years prior to the filing of this  Complaint.    39.  WWR and its employees or agents are excluded from the Class, as well  as the Court and its officers and employees.  Plaintiff does not know the number of  members in the Class, but believes the Class members number in the several  hundreds, if not more.  Thus, this matter should be certified as a Class action to assist  in the expeditious litigation of this matter.   40.  Plaintiff and members of the Class were harmed by the acts of WWR in  at least the following ways: WWR, 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 as discussed above.  Plaintiff and the Class  members were damaged thereby.   42.  The joinder of the Class members is impractical and the disposition of  their claims in the Class action will provide substantial benefits both to the parties  and to the court.  The Class can be identified through WWR’s records or WWR’s  agents’ records.   43.  There is a well-defined community of interest in the questions of law  and fact involved affecting the parties to be represented.  The questions of law and  fact to the Class predominate over questions which may affect individual Class  members, including the following:  i.  Whether, during the proposed class period, WWR or its agent(s)  placed any calls utilizing an artificial or prerecorded voice  messages to the Class (other than a message made for emergency  purposes or made with the prior express consent of the called  party) to any telephone number assigned to a cellular telephone  service;   ii.  Whether Plaintiff and the Class members were damaged thereby,  and the extent of damages for such violations; and   iii.  Whether WWR and its agents should be enjoined from engaging  in such conduct in the future.    45.  Plaintiff and the members of the Class have all suffered irreparable  harm as a result of the WWR’s unlawful and wrongful conduct.  Absent a class  action, the Class will continue to face the potential for irreparable harm.  In addition,  these violations of law will be allowed to proceed without remedy and WWR will  likely continue such illegal conduct.  Because of the size of the individual Class  member’s claims, few, if any, Class members could afford to seek legal redress for  the wrongs complained of herein.   46.  Plaintiff has retained counsel experienced in handling class action  claims and claims involving violations of the Telephone Consumer Protection Act.   48.  WWR has acted on grounds generally applicable to the Class, thereby  making appropriate final injunctive relief and corresponding declaratory relief with  respect to the Class as a whole.  49.  Plaintiff repeats and realleges the above paragraphs of this Complaint  and incorporates them herein by reference.   50.  Defendant negligently placed multiple calls to cellular numbers  belonging to Plaintiffs without Plaintiffs’ prior express consent using a  prerecorded voice and/or artificial messages.   51.  Each of the aforementioned calls by Defendant constitutes a negligent  violation of the TCPA.   52.  As a result of Defendant’s negligent violations of the TCPA, Plaintiff  and the Class are entitled to an award of $500.00 in statutory damages for each  call in violation of the TCPA pursuant to 47 U.S.C. § 227(b)(3)(B).   54.  Plaintiffs repeats and realleges the above paragraphs of this Complaint  and incorporates them herein by reference.   55.  Defendant knowingly and/or willfully placed multiple calls to cellular  numbers belonging to Plaintiffs without Plaintiffs’ prior express consent using  prerecorded voices and/or artificial messages.   56.  Each of the aforementioned calls by Defendant constitutes a knowing  and/or willful violation of the TCPA.   57.  As a result of Defendant’s knowing and/or willful violations of the  TCPA, Plaintiff and the Class are entitled to an award of treble damages up to  $1,500.00 for each call in violation of the TCPA pursuant to 47 U.S.C. §  227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).   Dated: October 3, 2018  Respectfully submitted,  By  /s/ David H. Krieger, Esq.  David H. Krieger, Esq.   Nevada Bar No. 9086  George Haines, Esq.  Nevada Bar No. 9411  Shawn Miller, Esq.  Nevada Bar No. 7825  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.)  