issue, see FCC’s Letter Brief, 2014 WL 3612689 at *10-*11, courts interpreting the excerpt agree with our reading. A debtor consents to calls about “an existing debt” when he gives his number “in connection with” that debt, 23 F.C.C. Red. at 564 — including after his initial signing of the loan. See Moore v. Firstsource Advantage, LLC, No. 07-CV-770, 2011 WL 4345703, at *10 (W.D.N.Y. Sept. 15, 2011). While debtors may “[t]ypically” give their cellphone number “as part of a credit application” at the beginning of the debtor — creditor relationship, see 23 F.C.C. Red. at 565 n. 36, it doesn’t have to be that way. Mais v. Gulf Coast Collection Bureau, Inc., 768 F.3d 1110, 1122 (11th Cir.2014); see, e.g., Sartori v. Susan C. Little & Associates, P.A., 571 Fed.Appx. 677, 683 (10th Cir.2014) (<HOLDING>). Unsurprisingly, then, a person gives his
holding that the debtor gave his prior express consent even though he didnt give his number until one year after debt was incurred holding that cost of plastic surgery to repair scarring was an expense incurred within one year of the accident even though the physician waited more than a year after the accident to perform the operation holding that debt orhusband could exempt his interest in home even though he lived elsewhere and even though the home was a residence only for his children and codebtor wife from whom he was separated holding that a third party did not give his prior express consent to be called about a debt when he gave his number outside of the context of the debt holding that defendant was not resident of his mothers household even though his drivers license listed his mothers address and he received mail there because he expressed a belief that his residence was in a different location than his mothers home he rented and occupied his own residence and he testified that he was only living with his mother after expiration of his lease until he could find another place to live