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UNITED STATES DISTRICT COURT 

Eastern District of Texas 

Sherman Division 

George Kenneth Schopp, 

Plaintiff,

§

§

§

§

§

CA No.: 4:23-cv-568

v. §

§ Class Action 

National Debt Relief, LLC 

Defendant. 

§

§

§

Jury Demanded 

PLAINTIFF GEORGE KENNETH SCHOPP’S 

CLASS ACTION COMPLAINT

George Kenneth Schopp (“Plaintiff”) brings this action to enforce the 

consumer-privacy provisions of the Telephone Consumer Protection Act 

(“TCPA”), a federal statute enacted in 1991 in response to widespread public 

outrage about the proliferation of intrusive, nuisance telemarketing practices. He 

is also suing under Section 305-053(c) of the Texas Business & Commerce Code 

and Section § 302.101 of the Texas Business & Commerce Code.

1. Background 

1.1. “Voluminous consumer complaints about abuses of telephone technology 

– for example, computerized calls dispatched to private homes – prompted 

Congress to pass the TCPA.” Id. at 744. In enacting the TCPA, Congress 

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intended to give consumers a choice as to how creditors and telemarketers 

may call them. Thus, and as applicable here, Section 227(b)(1)(A)(iii) of 

the TCPA specifically prohibits the making of “any call (other than a call 

made for emergency purposes or made with the prior express consent of 

the called party) using any automatic telephone dialing system or an 

artificial or prerecorded voice ... to any telephone number assigned to a ... 

cellular telephone service[.]” 

1.2. Plaintiff’s residential cellular telephone number (469-XXX-1358, the 

“Telephone Number”) is/was listed on the national Do Not Call 

Registry, a list explicitly designed to protect the public from these kind of 

intrusive telemarketing calls. Plaintiff listed the Telephone Number on the 

national Do Not Call Registry on December 11, 2004, and the Telephone 

Number has remained on the national Do Not Call Registry since that date. 

1.3. National Debt Relief, LLC (“Defendant”) or its telemarketing 

representative or lead generator called Plaintiff’s residential phone on 

approximately 12 occasions beginning on December 28, 2022, and made 

marketing solicitations, i.e., calls for the purpose of encouraging the 

purchase or rental of, or investment in, property, goods, or services. 

Specifically, Defendant attempted to sell Plaintiff Defendant’s debt relief 

services. 

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1.4. Because Plaintiff had not given his consent to receive these calls from 

Defendant, these calls violated the TCPA and the Do Not Call Registry 

laws and regulations. 

1.5. Because the calls were transmitted using technology capable of generating 

hundreds of thousands of telemarketing calls per day, and because 

telemarketing campaigns generally place calls to hundreds of thousands or 

even millions of potential customers en masse, Plaintiff brings this action on 

behalf of a proposed nationwide class of other persons who received illegal 

telemarketing calls from or on behalf of Defendant. 

1.6. A class action is the best means of obtaining redress for the Defendant’s 

wide scale illegal telemarketing and is consistent both with the private right 

of action afforded by the TCPA and the fairness and efficiency goals of Rule 

23 of the Federal Rules of Civil Procedure. 

2. Parties 

2.1. Plaintiff is a resident of this District. The calls were received in this District. 

2.2. Defendant is a Limited Liability Company with its principal place of 

business located at 180 Maiden Lane, 30th FL., New York, NY 10038. 

Defendant is engaged in a variety of services including debt counseling. It 

conducts business throughout the United States, and in and throughout the 

State of Texas. 

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3. Jurisdiction and Venue 

3.1. The Court has federal question subject matter jurisdiction over these 

TCPA claims. Mims v. Arrow Financial Services, LLC, 132 S. Ct. 740 (2012).

3.2. Venue is proper because the Plaintiff is a resident of this District and 

Defendant has sufficient contacts in this State and District to subject it to 

personal jurisdiction. Defendant made calls to a resident of this District. 

3.3. This Court has personal jurisdiction over Defendant because Defendant 

targeted a telephone number with a Texas area code (469) and called a 

resident of Texas. Plaintiff alleges that discovery will show that Defendant 

called and texted Texas area codes on numerous occasions. Thus, 

Defendant is aware that it is calling residents of Texas and dialing into the 

State of Texas. Defendant took these actions to establish contacts with the 

State of Texas.

3.4. This Court also has supplemental jurisdiction over the state law claims 

under 28 U.S.C. § 1367(a), because they are so closely related to the federal 

claims that they form a single case or controversy. 

4. Article III Standing 

4.1. Plaintiff has Article III standing for his claim under the TCPA. Spokeo, Inc., 

v. Thomas Robins, 136 S. Ct. 1540 (2016). See also, Morris v. Hornet Corp., 

No. 4:17-CV-00350, 2018 WL 4781273 (E.D. Tex. Sept. 14, 2018), report 

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and recommendation adopted, No. 4:17-CV-00350, 2018 WL 4773547 (E.D. 

Tex. Oct. 3, 2018). 

4.2. Plaintiff was harmed by Defendant’s actions of calling his residential phone 

while his number was on the Do Not Call Registry, without consent in the 

following manners: 

4.2.1. Plaintiff’s privacy was invaded by Defendant; 

4.2.2. Plaintiff was harassed and abused by Defendant’s telephone calls; 

4.2.3. Defendant’s calls were a nuisance to Plaintiff; 

4.2.4. Plaintiff’s phone was unavailable for other use while processing the 

illegal calls from Defendant; 

4.2.5. Defendant illegally seized Plaintiff’s telephone line while it made 

illegal calls to Plaintiff’s cellular telephone; 

4.2.6. Plaintiff’s telephone line was occupied by multiple unauthorized 

calls from Defendant; 

4.2.7. Defendant’s seizure of Plaintiff’s telephone line was intrusive; and 

4.2.8. Plaintiff was inconvenienced by Defendant’s calls, by among other 

things, hearing his ring and having to check the calling party. 

5. Factual Allegations; Defendant placed telemarketing calls to the Plaintiff 

5.1. Plaintiff is the owner of and user of the cellular telephone number 469-

XXX-1358. The cellular number is used as a residential phone number. The 

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cellular number is a cell phone that Schopp uses for personal, family and 

household use. Schopp maintains no landline phones at his residence and 

primarily relies on cellular phones to communicate with friends and family. 

Schopp also uses his cell phone for navigation purposes, sending and 

receiving emails, and sending and receiving text messages. Schopp further 

has his cell phone registered in his personal name, pays the cell phone from 

his personal accounts, and the phone is not primarily used for any business 

purpose.

5.2. Each of the telephone calls referenced below was made to Plaintiff’s 

residential telephone number 469-XXX-1358. None of the calls at issue 

were placed by Defendant to Plaintiff’s phone number for "emergency 

purposes." 

5.3. Beginning on December 28, 2022, Plaintiff began receiving telephone calls 

directly from Defendant or from Defendant’s telemarketing 

representatives who made the telephone calls as the agent for and on behalf 

of Defendant (all references herein to Defendant include Defendant’s 

telemarketing representatives). 

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5.4. The telephone calls were for the purpose of encouraging the purchase or 

rental of, or investment in, property, goods, or services. Specifically, 

Defendant was seeking to sell Plaintiff Defendant’s debt relief services. 

5.5. Plaintiff is not a customer of Defendant and has not provided Defendant 

with his written consent to be called. 

5.6. All the calls were placed to a telephone number that Plaintiff had listed on 

the National Do Not Call Registry for more than 31 days prior to the calls. 

5.7. All of the calls were made by Defendant or Defendant’s authorized agents 

and partners in Defendant’s solicitation scheme. Thus, all of the calls 

were made on behalf of Defendant. 

5.8. All of the calls used a prerecorded message such as Interactive Voice 

Response and/or Speech Recognition software. All of the calls had a similar 

pattern. Each call started with a “hello” from a female voice and awaited a 

voice response from the called party. Once the called party verbally 

responds the caller begins by introducing themselves with a female name 

and a prerecorded message regarding debt reduction and or debt 

elimination and selling debt relief programs. All of the calls then ask the 

caller if they would like to be transferred/connected to a live 

representative. 

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5.9. All of the calls followed the same pattern. On the 4-11-2023 call Plaintiff 

followed the prompts, spoke with an agent and was told that the agent was 

with National Debt Relief. On May 8, 2023 Defendant returned a call from 

Plaintiff and identified itself as national Debt Relief. 

5.10. Plaintiff received calls from Defendant on the following dates: 

Date of Call Received Time Prerecorded/Artificial Voice

12/28/2022 1:12 PM Yes

12/29/2022 2:31 PM Yes

1/16/2023 1:03 PM Yes

1/17/2023 9:22 AM Yes

1/19/2023 10:13 AM Yes

1/25/2023 11:11 AM Yes

3/2/2023 12:16 PM Yes

3/17/2023 4:09 PM Yes

3/21/2023 2:31 PM Yes

3/30/2023 3:59 PM Yes

4/11/2023 11:22 AM Yes

5/5/2023 2:33 PM Yes

5.11.Plaintiff believes he also received additional calls from Defendant and 

discovery will show the exact number of calls. 

5.12. All of the calls were willful and knowing violations of the TCPA as 

the Defendant was using spoofed phone numbers to make the calls to 

Plaintiff. This indicates that Defendant is aware that its calling practices 

are in violation of the TCPA. Defendant has also been sued before fr 

TCPA violations. 

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6. Class Action Allegations

6.1. As authorized by Rule 23 of the Federal Rules of Civil Procedure, Plaintiff 

brings this action on behalf of classes of all other persons or entities 

similarly situated throughout the United States and on behalf of a class of 

all other persons or entities similarly situated throughout the State of 

Texas. 

6.2. The class of persons Plaintiff proposes to represent with respect to Count 

One is tentatively defined as: 

6.2.1. Prerecorded/Artificial Voice Class: All persons in the United 

States from four years prior to the filing of this action through the 

present who (1) Defendant (or an agent acting on behalf of Defendant) 

called, (2) on the person’s cellular telephone, (3) using a prerecorded 

or artificial voice. 

6.3. The class of persons Plaintiff proposes to represent with respect to Count 

Two is tentatively defined as: 

Do Not Call Registry Class: All persons in the United States from 

four years prior to the filing of this action through the present who (1) 

Defendant (or an agent acting on behalf of Defendant) called more 

than one time, (2) within any 12-month period (3) where the telephone 

number had been listed on the National Do Not Call Registry for at 

least thirty days; (4) for the purpose of selling Defendant’s products 

and services. 

6.4. The class of persons Plaintiff proposes to represent with respect to Count 

Three is tentatively defined as: 

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Texas § 302.101 Class: From four years prior to the filing of this 

action through the date of certification, Plaintiff and all residents of 

the State of Texas to whose telephone number Defendant placed (or 

had placed on its behalf) a telephone solicitation when Defendant did 

not hold a registration certificate as required by Tex. Bus. & Com. 

Code § 302.101. 

 

6.5. The class of persons Plaintiff proposes to represent with respect to Count 

Four is tentatively defined as: 

Texas § 305.053 Class: : From four years prior to the filing of this 

action through the date of certification, Plaintiff and all residents of 

the State of Texas, to whose telephone number Defendant: placed (or 

had placed on its behalf) a call in violation of 47 U.S.C. § 227 or a 

regulation thereof. 

6.6. The classes as defined above are identifiable through phone records and 

phone number databases. 

6.7. Plaintiff does not know the exact number of members in the proposed 

classes, but reasonably believes based on the scale of Defendant’s business, 

and the number of calls that he received, that the classes are so numerous 

that individual joinder would be impracticable. The potential class 

members number at least in the hundreds or thousands. 

6.8. Plaintiff and all members of the proposed classes have been harmed by the 

acts of Defendant in the form of multiple involuntary telephone and 

electrical charges, the aggravation, nuisance, and invasion of privacy that 

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necessarily accompanies the receipt of unsolicited and harassing telephone 

calls, and violations of their statutory rights. 

6.9. Plaintiff is a member of the classes. 

6.10. There are questions of law and fact common to Plaintiff and to 

the proposed classes, including but not limited to the following: 

6.10.1. Whether Defendant violated the TCPA or the TBCC by engaging in 

advertising by unsolicited prerecorded or artificial voice 

telemarketing calls; 

6.10.2. Whether Defendant or its agents, within the four years before the 

filing of this Amended Complaint, made one or more one 

telemarketing calls to a recipient’s cell phone with the use of an 

artificial or prerecorded voice. 

6.10.3. Whether Defendant or its agents, within the four years before the 

filing of the initial Complaint, made one or more one telemarketing 

calls within any twelve-month period to individuals whose telephone 

number had been registered on the Do Not Call Registry for more 

than 31 days and made such calls without the consent of the recipient 

of the call. 

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6.10.4. Whether Defendant had the requisite registration certificate as 

required by Tex. Bus. & Com. Code § 302.101 when making 

telephone solicitations; 

6.10.5. Whether the Plaintiff and the class members are entitled to 

statutory damages as a result of Defendant’s actions. 

6.11. Plaintiff’s claims are typical of the claims of class members. 

6.12. Plaintiff is an adequate representative of the class because his 

interests do not conflict with the interests of the class, he will fairly and 

adequately protect the interests of the class, and he is represented by 

counsel skilled and experienced in class actions, including TCPA class 

actions. 

6.13. The actions of Defendant are generally applicable to the class as a whole 

and to Plaintiff. 

6.14. Common questions of law and fact predominate over questions 

affecting only individual class members, and a class action is the 

superior method for fair and efficient adjudication of the controversy. 

The only individual question concerns identification of class members, 

which will be ascertainable from records maintained by Defendant 

and/or its agents. 

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6.15. The likelihood that individual members of the class will prosecute 

separate actions is remote due to the time and expense necessary to 

prosecute an individual case. 

6.16. Plaintiff is not aware of any litigation concerning this controversy 

already commenced by others who meet the criteria for class 

membership described above. 

7. Count One: Violation of the TCPA’s artificial/prerecorded voice 

provisions 

7.1. Plaintiff incorporates the allegations from all previous paragraphs as 

if fully set forth herein. 

7.2. The Defendant violated the TCPA by initiating telephone solicitations to 

cell phone numbers with the use of an artificial or prerecorded voice. 

7.3. The Defendant’s violations were knowing/willful as Defendant was 

spoofing the calling phone numbers and had no prior business with 

Plaintiff. 

7.4. Relief Sought: For himself and all class members, Plaintiff requests the 

following relief: 

7.4.1. That Defendant be restrained from engaging in future 

telemarketing in violation of the TCPA. 

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7.4.2. That Defendant, and its agents, or anyone acting on its behalf, be 

immediately restrained from altering, deleting or destroying any 

documents or records that could be used to identify class members. 

7.4.3. That the Court certify the claims of the named plaintiff and all other 

persons similarly situated as class action claims under Rule 23 of the 

Federal Rules of Civil Procedure and Plaintiff’s counsel be named as 

counsel for the classes. 

7.4.4. That the Plaintiff and all class members be awarded statutory 

damages of $500 for each violation, with triple damages for any 

willful or knowing violation, as provided by the law. 

7.4.5. That the Plaintiff recover his attorneys’ fees and costs. 

7.4.6. That the Plaintiff and all class members be granted other relief as is 

just and equitable under the circumstances. 

8. Count Two: Violation of the TCPA’s Do Not Call provisions 

8.1. Plaintiff incorporates the allegations from all previous paragraphs as if fully 

set forth herein. 

8.2. Defendant made more than one unsolicited telephone call to Plaintiff and 

other members of the Do Not Call Registry Class within a 12-month period 

without their prior express consent to receive such calls. Plaintiff and other 

members of the Do Not Call Registry Class never provided any form of 

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consent to receive telephone calls from Defendant and do not have a 

current record of consent to place telemarketing calls to their registered 

phone numbers. 

8.3. The Defendant violated the TCPA by initiating telephone solicitations to 

persons and entities whose telephone numbers were listed on the Do Not 

Call Registry. See 47 U.S.C. § 227(c); 47 C.F.R. § 64.1200(c)(2). 

8.4. Defendant also violated 47 C.F.R. § 64.1200(d) by failing to have a written 

policy of dealing with do not call requests, by failing to inform or train its 

personnel engaged in telemarketing regarding the existence and/or use of 

any do not call list, and by failing to internally record and honor do not call 

requests. 

8.5. The Defendant’s violations were knowing/willful as Defendant was 

spoofing the calling phone numbers and had no prior business with 

Plaintiff. Defendant did not subscribe to or utilize the Do Not Call 

database. 

8.6. Relief Sought: For himself and all class members, Plaintiff requests the 

following relief: 

8.6.1. That Defendant be restrained from engaging in future 

telemarketing in violation of the TCPA. 

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8.6.2. That Defendant, and its agents, or anyone acting on its behalf, be 

immediately restrained from altering, deleting or destroying any 

documents or records that could be used to identify class members. 

8.6.3. That the Court certify the claims of the named plaintiff and all other 

persons similarly situated as class action claims under Rule 23 of the 

Federal Rules of Civil Procedure and Plaintiff’s counsel be named as 

counsel for the classes. 

8.6.4. That the Plaintiff and all class members be awarded statutory 

damages of $500 for each violation, with triple damages for any 

willful or knowing violation, as provided by the law. 

8.6.5. That the Plaintiff recover his attorneys’ fees and costs. 

8.6.6. That the Plaintiff and all class members be granted other relief as is 

just and equitable under the circumstances. 

9. Count Three: - Violations of Texas Business and Commerce Code, § 

302.101 (On Behalf of Plaintiff and the Texas § 302.101 Class) 

9.1. Plaintiff incorporates the foregoing allegations as if fully set forth herein. 

9.2. Defendant failed to obtain a registration certificate from the Office of the 

Secretary of State of Texas pursuant to § 302.101 of the Texas Business 

and Commerce Code. 

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9.3. Defendant placed telephone solicitations to Plaintiff’s and the Texas § 

302.101 Class Members’ telephone numbers. 

9.4. Defendant’s telephone solicitations were made from a location in Texas or 

to Plaintiff and the Texas § 302.101 Class Members located in Texas. 

9.5. Plaintiff and the Texas § 302.101 Class Members are entitled to an award 

of up to $5,000 for each violation and all reasonable cost of prosecuting the 

action, including court costs and investigation costs, deposition expenses, 

witness fees, and attorney’s fees. 

10. Count Four: Violation of Tex. Bus. & Com. Code, Chapter 305 

(“TBCC”) 

10.1. Plaintiff incorporates by reference all of the above paragraphs as 

though fully stated herein. 

10.2. Plaintiff is a “person” as defined by Texas Business & Commerce 

Code § 1-201(b)(27). 

10.3. Defendant is a “person” as defined by Texas Business & Commerce 

Code § 1-201(b)(27). 

10.4. Pursuant to Section 305-053(a) of the Texas Business & Commerce 

Code, a person who receives a communication that violates 47 U.S.C. 

§ 227, or a regulation adopted under that provision, may bring an 

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action against the person who originates the communication for an 

injunction, damages or both an injunction and damages. 

10.5. As set forth above Defendant violated 47 U.S.C. § 227, or a regulation 

adopted under that provision. 

10.6. Plaintiff is entitled to a permanent injunction to prevent any further 

violations of the Texas Business & Commerce Code, Chapter 305. 

10.7. Pursuant to Section 305-053(b) of the Texas Business & Commerce 

Code, Plaintiff is entitled to the greater of $500.00 for each violation or 

Plaintiff’s actual damages for each call negligently made by Defendant. 

10.8. Pursuant to Section 305-053(c) of the Texas Business & Commerce 

Code, Plaintiff is entitled to not more than the greater of $1,500.00 for 

each violation or three times Plaintiff’s actual damages for each 

violation by Defendant that the Court finds was made knowingly or 

intentionally. 

10.9. Relief Sought: For himself and all class members, Plaintiff requests the 

following relief: 

10.9.1. That Defendant be restrained from engaging in future 

telemarketing in violation of the TBCC. 

10.9.2. That Defendant, and its agents, or anyone acting on its behalf, be 

immediately restrained from altering, deleting or destroying any 

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documents or records that could be used to identify class 

members. 

10.9.3. That the Court certify the claims of the named plaintiff and all 

other persons similarly situated as class action claims under Rule 

23 of the Federal Rules of Civil Procedure and Plaintiff’s counsel 

be named as counsel for the classes. 

10.9.4. That the Plaintiff and all class members be awarded statutory 

damages of $500 for each violation, with triple damages for any 

willful or knowing violation, as provided by the law. 

10.9.5. That the Plaintiff recover his attorneys’ fees and costs. 

10.9.6. That the Plaintiff and all class members be granted other relief as 

is just and equitable under the circumstances. 

11. Count Five Injunctive relief to bar future TCPA violations 

11.1.Plaintiff incorporates the allegations from all previous paragraphs as if fully 

set forth herein. 

11.2.The TCPA and the TBCC authorize injunctive relief to prevent further 

violations of the TCPA. 

11.3.The Plaintiff respectfully petitions this Court to order the Defendant, and 

their employees, agents and independent distributors, to immediately cease 

engaging in unsolicited telemarketing in violation of the TCPA. 

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12. Jury Demand 

12.1. Plaintiff requests a jury trial as to all claims of the complaint so triable. 

Respectfully submitted: 

By: /s/ Chris R. Miltenberger

 Chris R. Miltenberger

 Texas State Bar Number 14171200

 

Designated as Lead Attorney

The Law Office of Chris R. Miltenberger, 

PLLC 

1360 N. White Chapel, Suite 200

Southlake, Texas 76092

817-416-5060 (office)

817-416-5062 (fax) 

chris@crmlawpractice.com

Attorney for Plaintiff 

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