10.  During the course of the aforesaid time period, and on multiple occasions therein,  Defendant initiated telephone calls to Plaintiff in an attempt to offer certain legal services to  Plaintiff.     11.  During each of the aforesaid telephone calls, Defendant played an artificial or  prerecorded voice message.    12.  Plaintiff does not currently have any accounts with Defendant.   14.  Plaintiff ascertained the multiple telephone calls were from Defendant by viewing  the telephone number on the caller identification on Plaintiff’s cellular telephone.   15.  The caller identification on Plaintiff’s cellular telephone identified that the  multiple telephone calls had originated from Defendant.   16.  The caller identification for the aforesaid telephone calls was 971-256-5661.   17.  Defendant knew or reasonably should have known Plaintiff would find  Defendant’s conduct, in initiating multiple telephone calls to Plaintiff’s cellular telephone, to be  harassing.    18.  Defendant knew or reasonably should have known Plaintiff would find  Defendant’s conduct, in initiating multiple telephone calls to Plaintiff’s cellular telephone, to be  abusive.    19.  Plaintiff was upset, frustrated and inconvenienced at Defendant’s conduct, as  delineated above, by it initiating multiple telephone calls to Plaintiff’s cellular telephone number.   20.  Plaintiff has been substantially damaged by Defendant’s telephone calls; her  privacy was improperly invaded, she was charged for the telephone calls, and she was annoyed  and frustrated by said calls.   21.  Defendant willfully and knowingly utilized an automatic telephone dialing system  to make and/or place telephone calls to Plaintiff’s cellular telephone number in an attempt to  offer Plaintiff certain legal services.   23.  Plaintiff re-alleges and incorporates by reference each of the preceding paragraphs  in this Complaint as though fully set forth herein.   24.  Plaintiff brings this claim on behalf of a class, consisting of:  All persons who, on or after June 2009, Defendant called to a cellular phone number  using predictive dialing equipment and/or a prerecorded or artificial voice where  Defendant did not obtain the phone number called from the called party, with respect to  the services offered by Defendant (for example, where the number was obtained through  skip tracing or captured by the Defendant’s equipment from an inbound call, or  Defendant was calling a wrong number).   25.  The class is so numerous that joinder of all members is impractical.  Upon  information and belief Plaintiff alleges that there are more than forty (40) members of the class.   25.  Plaintiff will fairly and adequately protect the interests of the class.  Plaintiff has  retained counsel experienced in handling class actions and claims involving unlawful business  practices.  Neither Plaintiff nor Plaintiff's counsel have any interests which might cause them not  to vigorously pursue this action.    26.  A class action is an appropriate method for the fair and efficient adjudication of  this controversy.  The interest of class members in individually controlling the prosecution of  separate claims is small because it is not economically feasible to bring individual actions.    27.  Management of this class action is likely to present significantly fewer difficulties  than those presented in many class actions, e.g. for securities fraud.   28.  Class action treatment is superior to the alternatives for the fair and efficient  adjudication of the controversy alleged herein. Such treatment will permit a large number of  similarly situated persons to prosecute their common claims in a single forum simultaneously,  efficiently, and without the duplication of effort and expense that numerous individual actions  would entail.    30.   As a result of Defendant’s conduct, Plaintiff and the class have been substantially  damaged by Defendant’s telephone calls; their privacy was improperly invaded, they were  charged for the telephone calls, and they were annoyed and frustrated by said telephone calls.   WHEREFORE, Plaintiff, DEBRA VEHLEWALD, On behalf of herself and all others  similarly situated, by and through her attorneys, respectfully prays for Judgment to be entered in  favor of Plaintiff and against Defendant as follows:  a.  Awarding Plaintiff, and all those similarly situated, all actual  compensatory damages suffered;  b.  Awarding Plaintiff, and all those similarly situated, statutory damages of  $500.00 per violation, pursuant to 47 U.S.C. §227(b)(3)(B);  c.  Awarding Plaintiff, and all those similarly situated, statutory damages of  $1500.00 per violation, pursuant to 47 U.S.C. §227(b)(3)(C);  d.  Awarding Plaintiff, and all those similarly situated, Plaintiff’s attorneys’  fees and costs; and,  e.  Awarding Plaintiff, and all those similarly situated, any other relief  deemed appropriate by this Honorable Court.  VI.  7.  In or around June 2013, and July 2013, and on multiple occasions therein,  Defendant initiated multiple telephone calls to Plaintiff.   8.  During the course of the aforesaid time period, the telephone calls initiated by  Defendant were placed to Plaintiff’s cellular telephone number.   9.  At the time Defendant initiated the aforesaid telephone calls to Plaintiff,  Defendant knew or reasonably should have known that the telephone number to which it was  calling was Plaintiff’s telephone number.   COUNT I:  DEBRA VEHLEWALD, INDIVIDUALLY V. CLAIM ASSISTANCE GROUP, LLC.   COUNT II:   DEBRA VEHLEWALD, ON BEHALF OF HERSELF AND ALL OTHERS SIMILARLY SITUATED, V.  CLAIM ASSISTANCE GROUP, LLC.   