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HomeMy WebLinkAbout07-3616IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS CIVIL ACTION c/o Edwin A. Abrahamsen & Associates, P.C. 120 North Keyser Avenue Scranton, PA 18504 vs. Plaintiff VERONICA KLINE 956 WERTZVILLE RD ENOLA PA 17025 Defendant NOTICE TU DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20)-days after this Complaint and Notice to Defend are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment maybe entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE; PA 17013 (800) 932-035E YJR (717) 243-9400 FAX: (717) 243-8026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS CIVIL ACTION c/o Edwin A. Abrahamsen & Associates, P.C. 120 North Keyser Avenue NO: d7 - ~ b ~ ~ Scranton, PA 18504 Plaintiff vs. VERONICA KLINE 956 WERTZVILLE RD ENOLA PA 17025 Defendant COMPLAINT Plaintiff, Unifund CCR Partners, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, UNIFUND CCR PARTNERS c/o Edwin A. Abrahamsen & Associates, P.C., (hereinafter "Plaintiff') is a Pennsylvania corporation with a principal place of business located at 120 North Keyser Avenue Scranton, PA 18504. 2. The Defendant VERONICA KLINE (hereinafter "Defendant") is an adult individual residing at 956 WERTZVILLE RD ENOLA PA 17025. 3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase and collection. 4. Defendant applied for and received a credit card issued by FIRST USA BANK with the account number 4253314658037818. 5. The within account was opened by Defendant with account number 4253314658037818 and was sold by FIRST USA BANK to Unifund for valuable consideration and all rights under said accounts were assigned to Unifund. (See, Bill of Sale, Affidavit and Assignment attached hereto as Exhibit "A.") 6. Use of the FIRST USA BANK. credit cazd was subject to the terms of the Cazdmember Agreement, a copy of which+:: was sent to the Defendant along with the credit card. (See, Copy of Cazdmember Agreement, attached hereto and mazked Exhibit ..B ~~~ 7. Defendant used the FIRST USA BANK credit cazd account number 4253314658037818, for purchases, cash advances and/or balance transfers. 8. The Defendant was mailed account statements relative to the Defendant's use of the subject credit cazd. 9. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 10. The account became delinquent on August 27, 2004. 11. The principal amount was $12,405.77 at the time it was received by Plaintiff. 12. Pursuant to the account agreement, any unpaid balance accrues interest at the rate of 6. 13. The total amount due and owing the Plaintiff including interest, is $14,473.96. 14. Pursuant to the terms of the Agreement, Defendant is liable for Plaintiffs court costs and reasonable attorney's fees in the amount of 25% of the balance. WHEREFORE, Plaintiffrequf:sts judgment in its favor and against Defendant in the amount of $14,473.96 plus costs of suit, reasonable attorneys' fees of $3618.49 and any other relief as the Court deems just and appropriate. Respectfully submitted, Edwin A. Abrahamsen & As fates, P.C. Michael F. R d, Es re Scott J. Best, Esquire Attorney I.D. Nos . 85/93600 120 N. Keyser ue Scranton, PA 504 VERIFIt:ATION I, Michael F. Ratchford, attorney for Plaintiff, Unifund CCR Partners, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify t}-;rt the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4>~4. AFFIDAVIT OF iINDEBTEDNES5 State of Ohio ) County of Hamilton) ss. Kim Kenney being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called assignee, which is doing business at 10625. Techwoods Circle, Cincinnati, Ohio 45242 and the statements and represernations herein are within her personal knowledge. The defendant is not in am branch of the military. There is due and payable from VERONICAKLINE, Account Number 4253314658037818, the amoum of $14323.05 (principal balance in the amount of $12405.77 plus nrterest up through 04/]0/2007 in the amount of $1917.28). By the terms of the agreemeirt between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 6.00 percent per annum. This balance reflects any payments, credits or offsets made since the account was charged off. Chase Bank USA NA's accoum was issued under the name of FIRST USA BANK. Unifimd CCR Partners _. purchased this account from Chase Bank USA NA. Said accourn has been referred to Law Ofcs of Edwin A. Abrahamsen & A with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim. DATED this Apri110, 2007 CCR PARTNERS By: Kim Kenney Media Supervisor 10625 Techwoods Circle Cincinnati, OH 45242 Address Subscribed aifd sworn t~ before me a!~..,~~inri DUwfr \~.~`~.~~~.:~.:::..Sl~~~''%,~~JEi~~IFER A• U6LIC ,.. .•. = STA , ExP~res Client # 1300 ;,..~ ~~. -Comm 2~p7 .; ~.. , - su~y d4, ~~ - ~'~~i~slgTE r i~F~~O~~ \\\\\` is 10 day of Ayril, 2007 Year My commission Expires ~~ ~~1-~IQtT 1300 ACCOUNT HUMBER BALANCE AS OF PAYMENT DUE DATE MINIMUM PAYMENT PAYMENT ENCLOSED 04M Of2007 4253314658037818 14,323.05 PAST DUE 14,323.05 IAdx Chedes P~ffile To IInILnE UNIFUND STATEMENT VERONICA KLINE 956 WERTZVILLE RD ENOLA PA 17025 MESSAGE FROM UNIFUND YOUR ACCOUNT IS PAST DUE $14,323.05. THE PAST DUEAMOUNT IS INCLUDED IN THEMINIMUM PAYMENT. PLEASE INFAEDIATELY. IF YOU HAVE ALREADY SENT A PAYMENT FOR THE ABOVE CMOUNT,THANK YOU. TRANSACTIONS: Date ~Transac#ion ~ IR ~~ Balance Due Payments New Balanc 44l10E2007 Chase Bank USA NA's Account 0.0600 14,323.05 14,323.05 0 14,323.05 Was Issued Under The Name Of FIRST USA BANK. PROMPT CREDITING OF PAYMENTS. TO RECEIVE CREDIT FOR PAYMENTS AS OF THE DATE OF RECEIPT. WE MUST RECEIVE YOUR CHECK OR MONEY ORDER AT: UNIFUND 10625 TECHWOODS GIRCLE CINCINNATI, OH 452A2 PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THEMANNER SPECIFIED AFTER THAT TIME WILL BE CREDITED TO YOUR ACCOUNT AS OF OUR NEkT 9USINESS DAY. THE CREDITING TO YOUR AICCOUNT OF PAYMENTS RECEIVED AT ANY LOCATION OTHER THAN THE ABOVEADDRESS MAY BE DELAYED UP TO 5 DAYS OF RECEIPT. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. FEDERAL LAW REQUIRES US TO INFORM YOU THAT THIS IS AN ATTEMPT TO COLLECT A DEBT AND AHY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CHASE ~r EXAIBIT A BILL OF SALE Chase Bank USA, N.A. (as successor through merger with Bank One, Delaware, N.A.) "Seller"}, for value received and pursuant to the terms and conditions of Credit Cazd Account Purchase Agreement dated January 26, 2006 between Seller and Unifund Portfolio A, LLC ("Purchaser"), its successors and assigns ("Credit Card Account Purchase Agreement"), hereby assigns effective as of the Cut-off Date of August 10, 2006 all rights, title and interest of Seller in and to those certain receivables, judgments or evidences of debt described in Exhibit 1 attached hereto and made part hereof for all purposes. Amounts due to Seller by Purchaser in hereunder shall be paid U.S. Dollars by a wire transfer to be received by Seller on August 21, 2006 (the "Closing Date") by 2:00 p.m. Seller's time, as follows: Chase Bank USA, N.A ABA #021000021 Beneficiary Name: Chase Bank USA, N.A. Beneficiary Account: #304256420 This Bill of Sale is executed without recourse except as stated in the Credit Card Account Purchase Agreement to which this is an Exhibit. No other representation of or warranty of title or enforceability is expressed or implied. Chase Bank U„SA,_N.A. Date: August 11.2006 _ Title Vice President Unifun ortfoGo , ILL ,. ,~' ~'" Date: Au t 11 2006 Title V~ ~ ~ j~:Ctt~'~ ~i ~ ~;-r,...~~.,.,,,°~::~ s~ 1 +~'ti.~,.:j ~X ~ ~ 8 lT ~- Page 2 of 2 Oct 112AOri ACCOUNT NUMBER: 4253 3146 5803 7818 PAYMENT DUE DATE NEVY BALANCE MINIMUM DUE 10J04/20Qd I $'12,149.18 I 54,320.18 11111 ~ a~~ VERONICA KLINE Aso 956 WERTZVILLE ROAD ENOLA PA 17025-1835 TIIl; $u'~ (F The Bank of New York Visa.:- Gold Y[ 112 K ACCOUNT NUMBER: 4253 3 146 58113 7818 - NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE 512,149.18 10/04/2004 $9,500 $0.00 09/09/2004 Here is your Account Summary: TOTAL Previous Balance $12,032.91 (-) Payments, Credits 254.00 (+) Purchases, Cash, Debits 99.00 (+) FINANCE CHARGES 271.27 (_) New Balance 12.149.18 Minimum Due 272.00 Past Due -Pay Immediately 1,399.00 Over Line -Pay Immediately 2,645.18 Minmum Payment Due $4,320.16 Here are your Charges and Credits at a glance: IRAN. DATE POST DATE REF. NO DESCRIPTION OF TRANSACTIONS CREDITS CHARGES 08127 OBlZ7 VXJ5 PAYMENT-THANK YOU 254.00 09!08 09108 1100 RETURNED PAYMENT FEE 29.00 09,09 09109 OVERLIMIT FEE 35.00 LATE CHARGE -MIN PYMT NOT RECD BY DATE 35.00 Total of your credits and charges 254.00 99.00 THIS IS THE LAST CHANCE TO PREVENT LONG TERM DAMAGE TO YOUR CREDIT RATING. CONTACT U3 NOW TO MAKE IMMEDIATE PAYMENT ARRANGEMENTS. Here's how we determined vout• Finance C6ar~e*: Days in Billing Cycle: 31 NOMINAL DAILY AVERAGE PERIODICfMIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.07258% 37,295.97 5164.16 5164.16 26.49% 26.49% Purchases 0.07258°k $4.760.39 $107.11 1107.11 26.49% 26.49% " Please see reverse side for balance computation method and other important information. Questions about your axount? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-444-9370 or write P.O. 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Faye ~ of 4 ~fivacy_PQlicy ~ ~eGUrify ~ Tz.rTtts, of_~se ~ ~2gal.Agreement5 ~ 2007 First USA ~XI-E1~jIT http://vs>Za>Zw, cardmemberser~~ices. corl~/ecp/index. jsp?pg_name=ccprr~app/cros!shared/page/te.rrns_r ... 3! 13/2f~07 AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton) ss. Kim Kenney being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and the statements and representations herein are within her personal knowledge. The defendant is not in airy branch of the military. There is due and payable from VERONICAKLINE, Account Number 4253314658037818, the amouirt of $14323.05 (principal balance in the amourn of $12405.77 plus interest up through 04/10/2007 in the amount of $1917.28). By the terms of the agreemern between the defendam and the original creditor, irnerest is accruing from the aforesaid date at the rate of 6.00 percent per annum. This balance reflects .any payments, credits or offsets made since the accourn was charged off. Chase Bank USA NA's accourrt was issued under the name of FIRST USA BANK. Unifund CCR Partners _ purchased this accoum from Chase Bank USA NA Said accourrt has been referred to Law Ofcs of Edwin A. Abrahamsen & A with full power and authority to do and perform all acts necessary for the collection, settlemern, adjustment, compromise or satisfaction of said claim. DATED this April 10, 2007 CCR PARTNERS By: Kim Kenney+ Media Supervisor 10625 Techwoods Circle Cincinnati. OH 45242 Address Subscribed a~fd sworn td before me ~''~ ,lE~ iFER UB ` '~~ ~'~ ,\ i f ti,.,. `` ~ NpSARY OHIO 5. ' ~ ~ / EXpl~es Cot : Client # 1300 = ~~ ~~ = ~, . m • o' 2007 y„iy d 4 , ~ .~ 10 day ofAyril, 2007 Year My commission Expires r ~~(~i~rT Page 2 of 2 PAYMENT DUE DATE NEW BALANCE M{NIMUM DUE 1 D104/2004 I 512,149.18 I 54,320.18 Oct 112006 ACCOUNT NUMBER: 42x3 3146 5803 7818 lull ~ ass VERONICA KLINE ~a 956 WERTZVILLE ROAD ENDLA PA 17025-1835 ~~F The Bank of New York Visa:: i Gald ~~~ ~~~ ~ ACCOUNT NUMBER: 4253 3146 5!3113 7N1A 1 \ Jli n NEW PAYMENT TOTAL TOTAL STATEMENT BALANCE DUE DATE CREDIT LINE AVAILABLE CREDIT CLOSING DATE $12,149.18 10/04/2004 59,500 $0.tit0 09/092004 Here is your Account Summary: TOTAL Previous Balance $12,032.91 (-) Payments, Criedits 254.00 (+} Purchases, Cash, Debtta 99.00 (+) FINANCE CHARGES 271.27 (_} New Balance 12.149.18 Minimum Due 272.00 Past Due -Pay Immediately 1,399.00 Over Line -Pay Immediately 2,649.18 Minimum Payment Due $4,320.18 u,. . rs... ...a r..e.~:M ~+ ~ nl~....o- TRAN. DATE POST DATE REF. NO DESCRIPTION OF TRANSACTIONS CREDITS CHARGES 08127 06127 VXJ5 PAYMENT-THANK YOU 2~•~ 09108 09108 1100 RETURNED PAYMENT FEE 29.00 09,09 09!09 OVERLIMIT FEE 35.00 LATE CHARGE -MIN PYMT NOT RECD BY DATE 35.00 Total of your credits and charges 254.00 99.00 THIS IS THE LAST CHANCE TO PREVENT LONG TERM DAMAGE TO YOUR CREDIT RATING. CONTACT US NOW TO MAKE IMMEDIATE PAYMENT ARRANGEMENTS. uo.•o~c 6nm wn rin4m•.r.innrl vnnr TiSnanro f h9mo*! nar;s m BillmQ Cycle: 31 NOMINAL DAILY AVERAGE PERIODIC/MIN. TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Cash 0.07258% $7,295.97 5164.16 3164.16 26.48% 26.49% Purchases 0.07258% y4,760.39 $107.11 $107.11 26.49% 26.49% " Please sea reverse side for balance computation method end other mportant intarmanon. Questions about your account? Credit Card lost or stolen? Call Chase Customer Service 24 hours a Day, 7 days a week, toll-free, at 1-800-444-9370 orvvrite P.O. BOX 15583, Wilmington, DE 19886-1184. Para Servicio al Clients en Espanol: 1-800-545-0464. Page t of t ~X~f~Q~T :1300 ACCOUNT NUMBER BALANCE AS OF PAYMENT DUE DATE MINIMUM PAYMENT PAYMENT ENCLOSED 04M 02007 4253314658037818 14,323.05 PAST DUE 14,323.05 ~"" AM2 Chetl~s P~ffile To YnlLna UNIFUND STATEMENT VERONICA ttLINE 956 WERTZVILLE RD ENOLA PA 11025 MESSAGE FROM UNIFUND UR ACCOUNT IS PAST DUE $14,323.05. THE PAST DUEAMOUNT IS INCLUDED IN THE MINIMUM PAYMENT. PLEASE R IMMEDIATELY. IF YOU HAVE ALREADY SENT A PAYMENT FOR THE ABOVE CMOUNT,THANK YOU. TRANSACTIONS: Date Transaction IR Balance Due P ents Hew Balarn Wm ._____ 04M 012007 Chase Bank USA NA's Account 0.0600 14,323.05 14,323.05 0 14,323.05 Was Issued Under The Name Of FIRST USA BANK. PROMPT CREDITING OF PAYMENTS. TO RECEIVE CREDIT FOR PAYMENTS AS OF THE DATE OF RECEIPT, WEMUST RECEIVE YOUR CHECK OR MONEY ORDER AT: UNIFUND 10625 TECHWOODS CIRCLE CINCINNATI, OH 45242 PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THEMANNER SPECIFIED AFTER THAT TIME WILL BE CREDITED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY. THE CREDITING TO YOUR ACCOUNT OF PAYMENTS RECEIVED AT ANY LOCATION OTHER THAN THE ABOVE ADDRESS MAY BE DELAYED UP TO 5 DAYS OF RECEIPT. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. FEDERAL LAW REQUIRES US TO INFORM YOU THAT THIS IS AN ATTEMPT TO COLLECT A DEBT AND AHY INFORMATION OBTAINED HALL BE USED FOR THAT PURPOSE. ~x~~~,T ~ Terms o ~ li se ~~~Member 5 8 f V 1 C 8 S FlrstTime User I Contact Us I Rage ?~ 0~4 ~i t:ardMember Services Terms of Use See your accot'nt ordine! Get a User ~Q These Terms of Use stale the terms and conditions that govern your !use of CardtdernberServices.com ("Untine Banking") offered by First USA ("FUSr'."). Vdhen you use or access, cr permit any other person ;s) to use or access Online Banking, you agree fo the ferms and ftE~urrsfn Usrra: Uri Ot~ ~i ±onoltlonS Gf thESE TEm??~ Di Use. FUSI, may amend or change these ~ Terms of use (including applicable fees and service charees) from User ID: time to time, in our sole discretion. by sending you written notice by tlectroric mail or by regular mail (sent toyeur address as it appears on your account records) a by posting the updated ferms on the sites i th " " t t d finks R Password: ew ese ). Flease access and rev Site(s) v.~ithin Online Banking (the e o a Terms of Use regularly. tf you rnd the Terrtis of Use unacceptable to ~ Identity Theft you at any time, please discontinue Vour use of Online Banking. ,. :Remember my User ID f Phis.hing, U~@r ~.t?IP_ass_w..ord N~ These terms and conditions are in addition to those that apply to 2ny - Fraudulent. E=mails. accounts you may have with F USA. Vk`nere appropriate, please review - Example Messages. those specific terms and condiiior.s. - privacy Policy As used in these Terms of Use, "you' or "your" refers to each person (s) subscribing to, using or accessing Ohtine Banking; "Card'--refers to your FUSA issued credit or debit card: and "we". "us", or "our' refers to FUSA and any agent. independent contractor, designee, or assignee FUSA may, at its sore discretion. involve in the provisioh of Online Banking. Online Banking. Online Banking is an online financial services webslle oftering a variety of content. products and services. FUSA grants to you. for your personal or internal business purposes only, a nonexclusive. limited and revocable right to access a+td use the Sites. Y'ou agree nol to use Online Banking for any other purpose. including commercial purposes. such as co-branding, framing or linking. without the FUSA's prior written consent. Fees. General access to Online Banking wi11 be provided to you free of charge. Howevr_r, you may incur fees if you use or obtain some of the produGs or services available through Online Banking. To learn more about such fees, please refer to the specific terms and conditions applicable to each product or service. Equipment. You are responsible for obtaining, installing, maintaining, and operating all computer hardware, software, and Internet access services necessary to use or access any aspect of Online Banking. FUSA wilt not be responsible for any errors or problems that arise From the malfunction ar failure of your hardware, software, or any Internet access services. Limitation of Access. We may terminate. suspend or limit your access privileges to Online Banking, in whole or in pars: in our sole discretion, at any time without prior notice. Account Information and Password Protection. To prevent unauthorized access to your accounts and ie prevent unauthorized use of Online Banking, you agree to protect and keep confidential your Card number, account number. PIN, User ID. Password, or other means of accessing your accounts to any person not authorized fo access your accounts. The loss, theft, or unauthorized use of your Card numbers, account numbers, PINs, User IDs, and Passwords could cause you to lose some or all of the money in your accounts, plus any amount available under your http:/h~v«~r.eardmemberservices.cont/ccp/index. j sp?pg_name=ccpmapp/ems/shared/page/terms_o 3/13/2007 Terms o~ L se ~a~dNlember s e r v i c e s see your accatnt oraFne! Get a Us€r tQ Rcr:urnirtg tJst~rs: L.~*~r; £~ User iD: r'Z35VVOfd: ?_= Remember my User !G U..~GL.LQIP_asswprd him =•LOg QA Flrst Time User I Contact Us I Terms of Use These Terms of Use stale the terms and conditions that govern your use of CardMember5ervices.com ("%;nline Banking") offered by First USA ("FUSr'+"). When you use or occess, or permit any other person (s) to use or access Online Banking, you agree to the terms end conditions of these Temts of Use. FUSA may amend or change these Terms of Use {including ~ppticable fees and service charges) from time to time, in cur sole discretion. b}' Sending you written notice by electronic mail or by regular mail sent to ,yeur address as it appears on your account records) or by posting the updated terms on the sites :within Online Bankino {the "Site(s)"). Flease access and review these Terms of Use regularly. if you rind the Terris of Usz unacceptable to you ai any fine, please discontinue your use of Online Banking. These terms and conditions are in addition to those that apply to any accounts you may have with FUSA. 1rt'here appropriate, please review those specific terms and conditions. As used in these Terms of Use, "you" or "yeur" refers to each person n~ (s) subscribing to, using or accessing Online Banking; "Card'-refers to your FUSA issued credit or debit card: and "we", "us", or "our" refers to FUSA and any agent. independent contractor, designee, or assignee FUSA may, at its sole discretion. involve in the provisioh of Online Banking. Online Banking. Online Banking is an online financial services website offering a variety of content. products and services. FUSA grants to you.. for your personal or internal business purposes only, a nonexclusive. limited and revocable right to access and use the Sites. Y'ou agree not to use Online Banking for any other purpose. including commercial purposes. such as co-branding, framing or linking. without the FUSA's prior written consent. Fees. General access to Online Banking will be provided to you free of charge. However, you may incur fees if you use or obtain some of the produGs or services available tluough Online Banking. To learn more about such fees, please refer to the specific terms and conditions applicable to each product or sen~ice. Equipment. You are responsible for obtaining, installing, maintaining, and operating all computer hardware, software, and Internet access services necessary to use or access any aspect of Online Banking. FUSA will not be responsible for any errors or problems that arise from the malfunction or failure of your hardware, software, or any Internet access services. Limitation of Access. We may terminate, suspend or limit your access privileges to Online Banking, in whole or in part.. in our sole discretion, at any time without prior notice. Page 1 of 4 I CardMember Services Related Links - Identi~ Theft - Phishing F Fraudulent E-mails - Exa~le Messages. - Privacy Policy Account Information and Password Protection. To prevent unauthorized access to your accounts and to prevent unauthorized use of Online Banking, you agree to protect and keep confidential your Card number, account number. PIN, User ID. Password, or other means of accessing your accounts to any person not aufhorized fo access your accounts. The loss, theft, or unauthorized use of your Card numbers, accoun! numbers, PINS, User IDs, and Passwords could cause you to lose some or all of the money in your accounts, plus any amount available under your http:/h>vv~~r.cardmemberservices.com/cep/index. j sp?pg_name=ccpmapp/cros/sharedJpage/terms_o... ~n 3/ZOOS Terms o`T use overdraft protection credit line, or dra+vs on your credit card account H you disclose your Card numbers, account numbers. PRJs, User IDs. andlor Passwords to any person(s) or entity, you assume all risks and losses associated vnttt such disclosure. If you permit any other person (s) or entity to use Online Banking or to access or use your Card numbers, account numbers. PINS. User IDs. Passwords, or other means to access your accounts, you are responsible for any transactions and activities authorized from your accounts. If you believe someone may attempt to use or has used Online banking without your permission. or that any other unauthorted use of your Card numbers, account numbers, PINS, User IDs and Passwords or security breach has occurred, you agree to immediately notih~ us by calling 1-80C,-482-3675 during normal customer service hours. P~~P ~, 0 4 Copyright and Trademark Notices. The imoees, text, screens. and web pages appearing on the In!ernet sttes wimin the Sites are owned try us, or ethers, as indicated and are protected by copyright laws. ~t'ou agre not to copy. display, distrib+>te, download, license, sub License, modify, publish, report, reproduce. reuse, soli. transmit. eagle a derivative work from or otherwise use for public or :,cmmercia purposes. the information and materials on the Sites, except as provided in ?agreement, without our express written permission. Unless etherv.^se noted. al; other trademarks, service marks, and loges used nn the Sites are the trademarks, service marks cr lo3os of FUSA., or others as indicated. ' Compliance. ' {n addition to these Terms of Use, you agree to comply vrith all applicable account agreements. including. without limitation, the C[edit Card Agreement Thal you received when opening your credit card account and with all applicable State and Federal laws and regulations. In the event of a conflict between the terms of these Terms of Use and your applicable account agreements with us. the terms of your account agreement will control. Damages. THESE TERMS OF USE STATE OUR ENTIRE t1ABILITY AND YOUR EXCLUSf~:'E RE1+9EDY AS IT RELATES TO ONLINE BANKING. IN NO EVENT SHALL FUS,4 OR ITS AFFILIATES BE LIABLE FOR ANti' LOSS. INJURY, OR DAh4AGES. WHETHER DIRECT, INDIRECT, SPECIAL, INCIDENTAL. EXEMPLARY. OR CONSEQUENTIAL. INCLUDING LOST PROFITS, ARISWG FROM OR RELATED TO ANY ACCESS TO OR USE OF OPJLINE BANKING, OR THE INSTALLATION, USE. OR MAINTENANCE OF YOUR PERSONAL COrdPUTER HARDWARE, EQUIPMENT. SOFTWARE, OR ANY INTERNET ACCESS SERVICES- Warranties Disclaimer. EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN ANY APPLICABLE AGREEMENT, YOU UNDERSTAND Ar`JD AGREE THAT YOUR USE OF ONLINE BANKING IS AT YOUR SOLE RISK AND THAT THE SERVICES AND ALL INFORMATION. PRODUCTS AND OTHER CONTENT (INCLUDING THIRD PARTY INFORMATION. PRODUCTS AND CONTENT) INCLUDED !N OR ACCESSIBLE FROM T.HE SITES, ARE PROVIDED ON AN "AS 15" "WHERE-IS" AND "WHERE AVAILABLE" BASIS. AND ARE SUBJECT TO CHANGE AT ANY TIME WITHOUT NOTICE TU YOU. YOU ACKNOWLEDGE THAT FUSA MAKES NU WARRANTY THAT THE SERVICES WILL 8E UNINTERRUPTED, T(MELY. SECURE OR ERROR-FREE UNLESS OTHERWISE STATED ON THE SITE OR IN ANY APPLICABLE AGREEMENT. TO THE FULLEST EXTENT PERh41TTED BY LAW, FUSA DISCt.A1rv1S ALL REPRESENTATIONS, IArARRANTtES AND CONDITIONS OF ANY KIND (EXPRESS, IMPLIED. STATUTORY OR OTHERWISE. INCLUCING BUT NOT uMITED TO THE WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT OF PROPRIETARY RIGHTS) AS TO ONLItJE BAtJKING AND ALL tNFORtv1ATION. PRODUCTS AND OTHER CONTENT pNCLUDING THIRD PARTY INFORMATION, PRODUCTS AND CONTENT) INCLUDED IN OR ACCESSIBLE FROM THE SITES. Slte Itnks. The Sites contain finks to other third party web sites. FUSA is not responsible for, nor does it control, the content, products, or services provided by linked sites. FUSA does riot endorse or guarantee the products, information or recommendations provided by linked sites, and is not liable for any failure of products or services advertised on -fix 1-~ ~3 ~ r http://~~vw. cartimemberservic es. comJecp/index. j sp'?pg_name=ccpm app,~cros;rsharedlpage/terms_o... 3 %13!? 007 Terr?~s e:~ L;' se Fade ~ of 4 those sites. to addition. each third party site may provide IeSS security than FUSA 2nd have a privacy policy different than that of FUSA four access. use and reliance upon such content, products or services is a1 vour own risk. Choice of LawlSuccessors. These Terms of Use and its enforcement shall be 9ovemed by the laws of the State of Illinois, without regard to any choice of law provision, and shall inure to the benefit of our successors and assigns, vdhether by merger, consolidation. or otherwise. The account(s) accessed via Online Banking shad be governed by laws of the applicable account agreements. Qispute Resolution'. Any claim, dispute, or controversy ("Claim") you have against us or our respective employees. agents, or assigns, cr we have against you. arising from or related in any way to these Terms of Use, inGudino claims regarding the application of this arbitration clause or the validity of the entire Agreement, shall be resolved by binding arbiiratior, by the National Arbitration Forum under the Code of Procedure in effect at the time the claim ,vas filed. Rules and forms of the National Arbitration Forum may be obtained and Gaims made may be ided at any tJationaf A.rbilration Forum Office. v,~ww.arbforum.com, or P.O. box 50191, Minneapolis, t•.~innesola 55405, telephone 1-EDO- 4 i 4.23,• t. Any arbitration hearing at which you appear wttl take place in Chicago. tltinois. This arbitration Agreement is made pursuant to a transaction im'olving interstate commerce, and shall be governed by the Federl Arbitration Act 9 U.S.C, §§ 1-9F. Judgment upon any arbitraticn w.'ard may be entered in any court having jurisdiction. This arbitration agreement applies to al! Claims now in existence or That may arise in the future except for Claims by or against any unarfiliated third party to which ownership of your account may be assigned after default (unless the party elects to arbitrate.) Nothing in these Terms of Use shat) be construed to prevent cur or your use of (or advancement of any Claims, defenses, or offsets in) bankruptcy or repossession. replevin. judicia; foreclosure. or other prejudgment er provisional remedy relating to any collateral. security, or property interests for contractual debts now o, hereinafter owned by either party to the other, under these Terms of Use. EXCEPT AS OTHERb'VISE PROVIDED ABOVE, YOU AND UJE AGP.EE TO WAIVE ANY' RIGHT YOU OR WE MIGHT OTHERWISE HAVE HAD TO A JURY TRIAL AhdD THE OPPORTUNITY TO LITIGATE CLAIMS IN COURT. BEFORE EITHER A JUDGE OR JURY OR TO PARTICIPATE IN A LA~NSUIT OR BE REPRESENTED BY OTHERS fN COURT QtJCLUDING CLASS A.CTIONS). 'AARP Cardmembers are not subject to arbitration as it relates to Dispute Resolution. Please refer to ydur Cardmember agreement( for your dispute resolution process. Indemnity. You acknowledge and agree that you are personally responsible for your conduct white using Online Banking and agree to indemnify and hold FUSA and its affiliates and their officers, directors, employees and agents harmless from and against any loss. damage, liability, cost or expense of any kind (including attorneys' fees) that we may incur in connection with a third party Gairn or otherwise, in relation to your use of Online Banking or your violation of these Terms of Use or the rights of any third party. Risk Of Loss. In the event of a system failure or interruption, your data may be lost or destroyed. Any transaction(s) that you initiated, were in the process of completing, er completed shortly before a system failure or interruption should be verified by you through means other than online to ensure the accuracy and completeness of such transaction(s). You assume the risk of loss of }'our data during any system failure or interruption and the responsibility to verify the accuracy and completeness of any transaction{s) so affected. Miscellaneous Terms. Not all of the products or services described on the Site(s) are available in all geographic areas. Therefore, you may not be eligible for all the products or services described. We reserve the right to determine your eligibility far any product or service. ~~~~~~~ ~ http:; /wvw~'.cardmemberservices.com/ccp/index. j sp?pg_name°ccpmapp!cros/shared/pageiterms_o... 3! 13/200? T Terns ~< .Ise Page ? of 4 Unless otherwise prohibited by law. any communication or material you transriit to us via fhe srle or Internet electronic mail is on a non- confidential basis end we may use such communication or material for any purpose consistent with ourPrn,~acy Pofiry, inGuding reproduction, publication. broadcast and posting. We w4tl not be deemed to have waived any of our rights or remedies under these Terms of Use unless such vraiver is in writing and signed by us. iJc delay or omission on our part in exercising any rights or remedies shat{ operate as a waiver of such rights or remedies or any other rights or remedies. A waiver on any one occasion shall not be construed as a bar or waiver of any rights or remedies on future occasions. Privacy_PgfCy ~ gecurity. ~ Temps. of IJsQ ~ .~egal,_Agres<menjs ~ 2DD7 ~irsi USA ~- X I-F l~j 1 T http a/v~~~~w. eardmemberservices.con~/ecp/index. j sp?pg_name=ccpmapp/cros!shared/page/terms_:~... 3! 13/2007 ~ ~. r'~ ~', n V _J (..;_- '~ ._r I, ?~ Or V ~ ~ ~ J= ~ ~, a -~ ~~~ ~~ _- ~- . '' r-•~ 3 SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-03616 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS KLINE VERONICA R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT KLINE VERONICA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND as to the within named DEFENDANT 956 WERTZVILLE ROAD KLINE VERONICA ENOLA, PA 17025 DEFENDANT HAS NOT LIVED AT GIVEN ADDRESS FOR 15 YEARS. Sheriff's Costs: Docketing 18.00 Service 14.40 Not Found 5.00 Surcharge 10.00 .00 G/.29/0 7 ~- / 4 7. 4 0 So answers: ~-- a r R. Th mas Kline S eriff of Cumberland County EDWIN A ABR.AHAMSEN & ASSOC 06/25/2007 Sworn and Subscribed to before me this day of A.D.