1. Identify that the call was an attempt to collect a debt;   10.  In July of 2014, DEFENDANT began placing calls to PLAINTIFF’s phone  number, in an attempt to collect a consumer debt from PLAINTIFF.   DEFENDANT left the  following pre-recorded message multiple times:  800-377-7679. Again the number is 1-800-377-7679. Thank you  and have a nice.   12.  DEFENDANT never sent PLAINTIFF an initial 1692g notice.   13.  PLAINTIFF is informed and believes and therefore alleges that PLAINTIFF and  the class members are entitled to statutory damages and may have also suffered damages in other  ways and to other extents not presently known to PLAINTIFF, and not specified herein.   PLAINTIFF reserves the right to assert additional facts and damages not referenced herein,  and/or to present evidence of the same at the time of trial.  14.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 13 inclusive, above.   15.  These claims for relief are brought by PLAINTIFF individually and on behalf of  the following classes:  a. Class Number One: A class consisting of nationwide consumers who:  i. Within one year prior to the filing of this action;  ii.  Received a pre-recorded message from DEFENDANT;  iii. Which failed to conform to 15 U.S.C. § 1692e(11) in that it did not:   16.  A class action is superior for the fair and efficient adjudication of the class  members’ claims as Congress specifically envisioned class actions as a principal means of  enforcing the FDCPA. See 15 U.S.C.§ 1692k.  The members of the class are generally  unsophisticated consumers, whose rights will not be vindicated in the absence of a class action.  Prosecution of separate actions by individual members of the classes would also create the risk  of inconsistent or varying adjudications resulting in the establishment of inconsistent or varying  standards and would not be in the best interest of judicial economy.    17.  If facts are discovered to be appropriate, PLAINTIFF will seek to certify the class  under Rule 23(b)(3) of the Federal Rules of Civil Procedure.  18.  PLAINTIFF repeats, re-alleges and incorporates by reference, paragraphs 1  through 17 inclusive, above.   19.  A debt collector is required to disclose in the initial communication “that the debt  collector is attempting to collect a debt and that any information obtained will be used for that  purpose” and in subsequent communications “that the communication is from a debt collector”.  15 U.S.C. §1692e(11).   2. Identify that any information obtained will be used for that  purpose; nor   21.  In July of 2014, DEFENDANT began placing calls to PLAINTIFF’S phone  number in connection with the collection of a consumer debt.  DEFENDANT left the following  pre-recorded message on PLAINTIFF’S cell phone multiple times:  800-377-7679. Again the number is 1-800-377-7679. Thank you  and have a nice   22.  DEFENDANT’s pre-recorded message fails to identify the name of the debt  collector in an attempt to trick the consumer into calling DEFENDANT back.   23.  Further, DEFENDANT’s pre-recorded message fails to identify that the call was  an attempt to collect a debt and that any information obtained will be used for that purpose, or  that the communication was from a debt collector.   24.  As a result of the FDCPA violations by DEFENDANT, PLAINTIFF is entitled  to an award of statutory damages.    25.  It has been necessary for PLAINTIFF to obtain the services of an attorney to  pursue this claim, on behalf of herself and those similarly situated, and is entitled to recover  reasonable attorneys’ fees therefor.  26.  PLAINTIFF repeats, re-alleges and incorporates by reference, paragraphs 1  through 25 inclusive, above.   28.  Here, DEFENDANT failed to send PLAINTIFF an initial collection letter  notifying PLAINTIFF of her rights pursuant to §1692g(a).    29.  As a result of the FDCPA violations by DEFENDANT, PLAINTIFF is entitled  to an award of statutory damages.    30.  It has been necessary for PLAINTIFF to obtain the services of an attorney to  pursue this claim, on behalf of herself and those similarly situated, and is entitled to recover  reasonable attorneys’ fees therefor.  9.  PLAINTIFF repeats, re-alleges, and incorporates by reference, paragraphs 1  through 8 inclusive, above.    VIOLATIONS OF THE FDCPA 15 U.S.C. §§ 1692d(6) and e(11)   BROUGHT BY PLAINTIFF INDIVIDUALLY AND ON BEHALF OF  CLASSES NUMBERS ONE AND TWO   VIOLATION OF THE FDCPA 15 U.S.C. § 1692g(a)  BROUGHT BY PLAINTIFF INDIVIDUALLY AND ON BEHALF OF  CLASS NUMBER TWO  