35.  Plaintiff re-alleges all of the above paragraphs of this Complaint and  incorporates them by this reference as though fully stated herein.   36.  Each of the aforementioned calls by Defendant constitutes a negligent  violation of the TCPA, including each of the aforementioned provisions of 47 U.S.C. §  227, et seq.   38.  Plaintiff re-alleges all of the above paragraphs of this Complaint and  incorporates them by this reference as though fully stated herein.   39.  Defendant’s acts as detailed herein constitute numerous knowing and/or  willful violations of the TCPA, in that the calls placed by Defendant were made  without prior express consent of Plaintiff and other members of the Class.   40.  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 in an amount up to  $1,500.00 for each and every knowing and/or willful violation of the TCPA pursuant to  47 U.S.C. § 227(b)(3)(B) and 47 U.S.C. § 227(b)(3)(C).  6.  Within the last four years, Cavalry placed telephone calls to Plaintiff on his  cellular telephone.   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.  