1. An award of the maximum statutory damages for Jerry K. Wong  and the Plaintiff Class pursuant to 15 U.S.C. §1692k;   11. As more particularly set forth infra at Paragraphs 12-13, within the one year immediately  preceding the filing of this Complaint, GT placed telephone calls to the Plaintiff and left  telephonic voice messages on his cellular voicemail system (“Messages”).   12. On June 28, 2013, being within one year immediately preceding the filing of this  Complaint, the Plaintiff received the following message on his cellular voicemail system  which could only be left by dialing his cellular telephone number, the voice message was  15 seconds in duration, and is transcribed as follows:  “This message is for Jerry Wong, Jerry this is Daniel from    Greentree, sir I need a call back from you today, my number  is 877-808-0048 my direct extension is 86428 give me a call   back at your earliest convenience sir I will be in the office   until 8, thank you, have a good one.”   13. On December 4, 2013, being within one year immediately preceding the filing of this  Complaint, the Plaintiff received the following message on his cellular voicemail system  which could only be left by dialing his cellular telephone number, the voice message was  10 seconds in duration and is transcribed as follows:  “This message is for Jerry Wong, my name is Calandra I’m calling from    Greentree please give me a call at 855-892-8914”   14. In leaving the voice messages, GT sought to collect a debt incurred for personal, family  or household purposes, namely fees emanating from a personal mortgage loan.    16. Each of the voice messages transcribed in Paragraphs 12-13 qualifies as a  “communication” as that term is defined by 15 U.S.C. §1692a(2).   17. The mortgage loan went into default in November 2012. (Annexed and attached hereto as  “Exhibit A” is a monthly billing statement from Bank of America dated November 29,  2012 and received by the Plaintiff which states in bold letters, “Our records indicate that  your loan is in default”)   18. Bank of America transferred servicing rights on the mortgage loan to GT on April 1,  2013 (Annexed and attached hereto as “Exhibit B” is a letter dated March 9, 2013 from  Bank of America. stating that Bank of America. was transferring servicing rights on the  mortgage loan to GT effective April 1, 2013)    19. GT formally took over serving of the loan on April 1, 2013.    2. Attorney’s fees, litigation expenses and costs of suit pursuant to 15  U.S.C. §1692k; and    20. At the time GT made the phone calls and left the Messages, GT was a debt collector as  defined by the FDCPA as it pertains to its relationship with the Plaintiff because GT  began servicing the mortgage loan after the debt was already in default.    21. The telephone numbers “877-808-0048” and “855-892-8914” which were the number left  on the voicemails transcribed in Paragraphs 12-13 are answered by employees of GT.  When returning phone calls to GT there is no precursor or automated message played  informing anyone who calls that GT is a debt collector before being allowed to speak to a  representative from GT.   3. Such other and further relief as the Court deems proper.  33. Plaintiff brings this action on behalf of a class, pursuant to Federal Rules of Civil  Procedure Rule 23(a) and 23(b)(3).   34. The class consists a) of all individuals with a New Jersey address for whom GT left a  message on the person’s telephone answering device in connection with the collection of  a mortgage loan that was in default when GT took over servicing of the mortgage loan,  which message failed disclose that the communication was from a debt collector b) on or  after a date one year prior to the filing of this action and on or before a date 20 days after  the filing of this action.   35. Upon information and belief the identities of all class members are readily ascertainable  from the records of GT.   36. Excluded from the Plaintiff Class are the Defendants and all officers, members, partners,  managers, directors, and employees of GT and their respective immediate families, and  legal counsel for all parties to this action and all members of their immediate families.   37. There are questions of law and fact common to the Plaintiff Class, which common issues  predominate over any issues involving only individual class members. Those principal  issues are whether the Defendants’ telephonic voice messages, such as the Messages  transcribed in Paragraphs 12-13 of this Complaint, violate 15 U.S.C. §1692e(11).   38. The Plaintiff’s claims are typical of the class members, as all are based upon the same  facts and legal theories.   41. Certification of a class under Rule 23(b)(3) of the Federal Rules of Civil Procedure is  also appropriate in that the questions of law and fact common to members of the Plaintiff  Class predominate over any questions affecting an individual member, and a class action  is superior to other available methods for the fair and efficient adjudication of the  controversy.   