HomeMy WebLinkAbout09-20930
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY,
PENNSYLVANIA
CACH, LLC.
VS. NO: d q- ;?o93 et4 izl ^I'?
NATALIE P KEANE
NOTICE TO DEFEND
You have been sued in Court. If you wish to defendant against the claims set fourth in
the following pages, you must take action within (20) days after the Complaint and notice
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 fourth against you.
You are warned that if you fail to do so, the case may proceed without you and a
judgment may be entered against you by the Court without further notice of any money
claims or 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 THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE.
LAWYER REFERRAL SERVICE
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013.
(717) 240-6200
Harrison Ross Byck, Esq., P.C.
229 Plaza Boulevard
Suite 112
Morrisville, Pennsylvania 19067
1-888-275-6399/(215) 428-0666
Attorney for Plaintiff
#61511
CACH, LLC.
4340 SOUTH MONACO STREET 2ND
FLOOR
DENVER, CO 80237
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
VS.
No.: G q. a o of 3 C -.?4
NATALIE P KEANE
110 E COUNTRYSIDE DR
BOILING SPRINGS, PA 17007
COMPLAINT
To: NATALIE P KEANE
110 E COUNTRYSIDE DR
BOILING SPRINGS, PA 17007
NOTICE
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
are served. By entering a written appearance personally or by 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 the court without further notice may enter
a judgment against you for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose 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.
LAWYER REFERRAL SERVICE
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013.
(717) 240-6200
AVISO
Le han dernandado a usted en is corte. Si usted quiere defenderse de estas demandas
expuestas en las pagins siguientes. Usted tiene veinte (20) dias de plaza al partir de la fecha de la
demanda y la notificacion. Hace falta asentar una comparencia excrita o en persons o con
abogado y entregar o sus objecciones a las demandas en contra de su persona. Se avisado que si
usted no se defiende. La corta tomara medidas y puede continuer la demada en contra suya sin
previo Avisa o notificion. Ademas la cone puede decidie a favor del demandante y requiere que
usted compla con todas las provisions de esta demanda. Usted puede perder dinero o sus
propiedas o otros derechos imporrantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO O SI NO TIENE EL DINERO
SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSOAN O LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRUA ABAJO
PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
SERVICE DE REFERENCIA LEGAL
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013.
(717) 240-6200
Plaintiff, CACH, LLC., by its attorney Harrison Ross Byck, by way of complaint against
Defendant NATALIE P KEANE, avers the following:
1. Plaintiff, CACH, LLC., is a Colorado limited liability company doing business at
4340 SOUTH MONACO STREET 2ND FLOOR, DENVER, CO 80237.
1. Defendant, NATALIE P KEANE, is an individual residing at 110 E
COUNTRYSIDE DR, BOILING SPRINGS, PA 17007.
2. The claims raised in the complaint are subject to an agreement to submit these
claims to arbitration. <Exhibit C>
3. Defendant, NATALIE P KEANE, is indebted to BANK OF AMERICA, N.A. on
an account stated by and between them in the amount of $5,673.74 which balance
was due and unpaid as of July 30, 2007, for credit card account number
4888930990829605. <Exhibit A>
4. On or about September 4, 2007, BANK OF AMERICA, N.A. sold the debt for
good and valuable consideration to plaintiff, CACH, LLC. <Exhibit B>
5. The Defendant, Natalie P Keane, last tendered a payment on May 31, 2007.
6. A copy of the credit card agreement is attached hereto. <Exhibit C>
7. Plaintiff is entitled to charge-off account finance charges of $0.00. <Exhibit A>
8. Plaintiff is entitled to pre-litigation charge-off interest of $5.0115 per day from the
default date ( 32.240% annual percentage rate x $5,673.74 / 365 days) or $5.0115 x
560 days = $2,806.46; which is accrued interest through the date of filing. <Exhibit
A> Plus an award of late fees 0.00, court costs $178.50 and reasonable attorneys fees
of $1,134.75 as stated in the Cardholder Agreement attached hereto as <Exhibit C>.
9. The defendant, being indebted to the plaintiff in the sum of $9,793.45 upon the
account stated by and between them did promise to pay said sums upon demand.
Demand has been made for payment of $9,793.45 and the defendant has failed to
remit payment.
WHEREFORE, plaintiff demands judgment against the defendant for $9,793.45 together
with other interest and costs of suit.
Date: March 17, 2009
EXHIBIT A
Prgafiradlbr. NATALIE P KEANE
4024 2320 0091 8113
July 2007 Statement Bankofftwt a?
Croal'7Lina 54,100.00
Cash orCraditAvailabla-
Billin
C
cle and P t I
d
di MAYPIlsnb1'aI
Sum of Transactions g
y
aymen on
r
ormat BANK OF AM
Previous Balance $5,141.69 Da in Billing Cycle
Y8 30 P.O. Box 15726
2e
Payments and Credits - $762.00 Closing Date 07/20/07 WILMINGTON, DE 19886.5728
Cash Advances * $853.00 Awe tp?rrqususAw
Purchases and Adjustments + $156.00 P rtt Due Date
aYms 08/18/07 BANK OF AMEWCA
Periodic Rate Finance Charges + $146.05 Current Payment Due $AO P.O. Box 15028
Transaction Fee Finance Charges + $0.00 Past Due Amount + $1,85.00 WILMINGTON, DE 1050.5026
634
74
$5 Total Minirmsm Call toll-free 1-800-788-8685
New Balance Total ,
. Payment Due TOD howl -implied 1-800-348-3178
Posting Transaction Reference Account
Rw%r o r mmomes rRumpon lq% t:.gtlw ll9 ' measaiM': „ • :: " s -aF ; y: a
PAY BY PHONE PAYMENT 07/02 1 00.0D C
* R
PAYMENT - THANK YOU 07AN ! 190.00 CR
Purdhasss and
Y 08/18
" 191.00
RETURN CHECK FEE 00M 08/22 INIM C 39,00
OYM
M 11 11111111111001110w /O9
08/30.; ;.
:j'441,40
RETURN CHECK FEE 07/09 07/08 8382 C 39.00
F'AY' iE7tf;INPAID t '07/09 OTdlit9lili'ilili B
RETURN CHECK FEE 07/09 07109 8801 C 39.00
LIT FORAWWNT DUE 07/15 . ; ° '•:9 ... " tic:. +tn ,. °?,
PAYMENT RETURNED
U
D
NPPAAII 7
07111 07/09 9286 B 191.00
?
?{
(
?1 q{1.?CifR1fA[{IP??
P ITR ED y ?
+
j
WI•/1bS at?i? ... 3.ki !FC 100.00
FINANCIAL, R11011ARDS POINTS
0 EARNm THIS PERIOD
0 RaDEMM TRIO PERIOD
0 TOTAL POINTS AVAILABLE
CALL 2.800.598.5665 TO REDENN Of VISIT
1 11.8if111MA1aRICA.CORK/FINANCIALVinu DS
CahQory Ax/odev Rats As/cartigps Rats Finaracs Chas
Cash Advances
A. Balance Transters, Checks 0.088328% DLY' 3224% $0.00
B. ATM, Bank 0.088328% DLY' 3224% $278.89
C. Purchases 0.088328% DLY' 3224% .73
Annual Percentage Rate for this itling Period: 32.24%
cdPeriodRate Fnance Chargott endTrerlsaction Fee Finance Chases.)
e may vary -
17 0056347400193400000148640004888930024871193
BANK OF AMERICA L] Check hen for a change of rreisp oWreee or phone nurrbekil.
Plan mvkle ON eorrectiofn on the Mmn WL
P.O. HOT 15726
? ¦?
WILMINGTON, , DE DE 19886-5726
fru111a1n111111n1rr??na?a?e?raa?n?r?rfile lolls I ACCOUNTNIJMEE& 4024 2320 0091 1H 13
NEW BALANCE TOTAL: $5,834.74
PAYMENTDUEDATE.' 08/18/07
NATALIE P KEANE
110 E COUNTRYSIDE DR
BOILING SPRINGS PA 17007--9447
f: 5 240 2 2 2501:
DOW ArnrYAMAWbmY..s
ypamsymbrenr C04otonBAalongNKwlrh a
check ornmoneOoWmnvso
Eaayabb to: OfAAIER/CA
1213 700 248 7 i 19 Us
A
BaskofAnmica?
FreP&wdfor NATAUE P KEANE July 2007 Statement
CAMW L#W :4.100.00
4024 2320 0091 8113 Cash or 0v4*Av&*bAm
OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE
YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS
EXHIBIT B
CERTIFICATE OF PURCHASE
JESSICA SNODGRASS
I, , hereby depose and state that:
1. I am an Authorized Agent of CACH, LLC, a Colorado Limited Liability
Company.
2. As such, I am authorized to give this Certificate, and possess sufficient
personal knowledge to do so regarding:
Customer Name: NATALIE P. KEANE
Original Creditor: BANK OF AMERICA, N.A.
Account Number: 4888930990829605
3. On or about September 4, 2007 this account was sold by the original creditor.
CACH, LLC is the current owner of the account and purchased the account for
g o o d a n d v a l u a b l e c o n s i d e r a t i o n.
Date: FEB 0 5 2009
.2009.
STEPHANIE MORRIS
NOTARY PUBLIC
STATE OF COLORADO
My Commission Expires 05/22/2011
PA 5.15.08
EXHIBIT C
FEDERALLY REQUIRED AFFILIATE MARKETING NOTICE
YOUR CHOICE TO LIMIT MARKETING
The Bank of America companies listed (see below)
are providing this notice.
Real Estate
HomeFocus Services, LLC
Administrative Services
LaSalle Healthcare Administrative Services, LLC
Federal law gives you the night to limit some but not Merchant Services
all marketing from all the Bank of America BA Merchant Services, LLC
affiliated companies. Federal law also requires us to LaSalle Merchant Services, LLC
F ve you this notice to tell you about our choice to
mit marketing from all the Bank of-America
affiliated companies.
You may limit all the Bank of America affiliated
companies, such as the banking, loan credit card,
insurance and securities companies, from marketing
their products or services to you based upon your
personal information that they receive from other
Bank of America companies. This information
includes your income, your account history, and your
credit score.
Your choice to limit marketing offers from the Bank
of America affiliated companies will apply for at
at 5 years from when you tell us your choice.
Before your choice to limit marketing offers expires,
you will receive a renewal notice that will allow you
to continue to limit marketing offers from all the
Bank of America affiliated companies for at least
another 5 years.
You may tell us your choice to Iimit marketing
offers, and you may tell us the choices for other
customers who are joint account holders with you.
41 This limitation will not apply in certain
circumstances, such as when you have an account or
service relationship with the Bank of America
company that is marketing to you.
For individuals with business purpose accounts, this
limitation will only apply to marketing to
individuals and not marketing to a business.
To limit marketin offers, contact us at 800.374.2632
Effective October 1,008
Banks and Trust Companies
Bank of America, NA.
LaSalle Bank National Association
LaSalle Bank Midwest National Association
Credit Card
Bank of America Consumer Card Services, LLC
Bank of America
Fleet Credit Card Services, L.P.
Insurance and Annuities
BA Insurance Services, Inc.
Banc of America Agency of Texas, Inc.
Banc of America Insurance Services, Inc.,
dba Banc of America Insurance Agency
General Fidelity Insurance Company
General Fidelity Life Insurance Company
LaSalle Financial Services, Inc.
dba LaSalle Insurance Services
Brokerage and Investments
BACAP Alternative Advisors, Inc.
Bank of America Capital Advisors LLC
Banc of America Investment Advisors, Inc.
Banc of America Investment Services, Inc.
Banc of America Securities LLC
LaSalle Financial Services, Inc.
U.S. Trust Hedge Fund Management, Inc.
UST Securities-Corp.
w
c .
?v
(continued)
BANK OF AMERICA PRIVACY POLICY FOR CONSUMERS 2008
To learn more about how Bank of America manages
Customer Information and what actions you can take,
please continue reading.
This document includes information about:
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8. Bank of America companies
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by the Federal Financial Privacy Law and applies to our
companies identified in Section 7, Bank of America
coin antes.
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?istl
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Bank of America is made up of a number of companies,
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al
Information we collect about each of your (1) Bank of
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• Financial services companies (such as insurance
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Review your monthly account statements and report
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Do not respond to a-mails requesting account
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• Memorize PINa and refrain from writing PINS,
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• For additional information on protecting your
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Beeping up to date with our Privacy Policy
We may make changes to this policy at any tune and will
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at: bankofamerica.com/privacy or call us at 1.888.341.5000.
of America companies
a Policy applies to the following Bank of America
a that have consumer customer relationships:
of Delaware, N.A.
A.
Consumer Card Services, LLC
. Services, L.P.
LLC
Inc..
ors, Inc.
:es, Inc.
:went, LLC
Management, Inc.
Advisors LLC
isurance Services, Inc.
of America Agency, LLC
of America Agency of Nevada Inc.
of America Agency of Texas, tnc.
of America Insurance Services, Inc., dba Banc of
Insurance Agency, LLC
Company
ance Company
HomeFocus Services, LLC
NatfonsCredit Financial Services Corporation
For a current list of Bank of America companies that have
consumer customer relationships and to which this policy
applies, please visit our Web site at
bankofamerica.com/privacy This policq ap li es to consumer
customer relationships established in the United States and
is effective January 1 2008. This notice constitutes the
Bank of America Uo loot Call Policy under the Telephone
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to state law.
You may have other privacy protections under state laws;
such as Vermont and California. To the extent these state
laws apply, we will comply with them with regard to our
information practices.
For Nevada residents only. Nevada law requires that we
also provide ou with the followingg ?? _c_ontact information:
Bureau of Consumer Protection, Of?'ice of the Nevada
Attorney General, 555 East Washington Street, Suite 3900,
?u
v'
NV 89101; phone number: 702.486.3132; e-mail:
a?.state.nv.us..Bank of America, PO Box 25118,
For Vermont and California residents only. The
information sharing practices described above are in
accordance with federal law. Vermont and California law
place additional limits on sharing information about
Vermont and California residents so long as they remain
residents of those states.
Vermont: In accordance with Vermont law Bank of
America will not share information we copied about
Vermont residents with -companies outside of Bank of
America, except as permitted by law, such as with the
consent of the customer, to service the customer's accounts
or to other financial institutions with which we have Joint
marketing agreements. Bank of America will not share
Application information Consumer Report Information and
information from Outside Sources about Vermont residents
among the Bank of America companies except with the
authorization or consent of the Vermont resident.
California: In accordance with California law, Bank of
America will not share information we collect about
California residents with companies outside of Bank of
America, except as permitted by law, such as with the
consent of the customer, to service the customer's accounts,
or to fulfill on rewards or benefits. We will limit sharing
among our companies to the extent required by applicable
California law.
Estas normal estdn dWonibles en espanol a travOa de la
sucursal bancaria de su localidad
0 2007 Bank of America Corporation.
CREDIT CARD AGREEMENT
YOUR CONTRACT WITH US Promise To Pay, and How We Allocate Your Pa meats)
y
We reserve the right to change the terms of this OTHER TERMINOLOGY
Agreement at an time, as rlher described in the We will use the definitions described under the section
section titled We May Amend is Agreement. heading Words Used Often In This Agreement or as
WORDS USED OFTEN IN THIS AGREEMENT term in thiis defined n butAwe do not define the termlinltt ds
"Access check" means a check we provide to you to obtain monthlygs'tatement m has the meaning as used in your
credit on your account.
"Agreement" or "Credit Card Agreement" means this ?e use ent)cto organize headings this agreement. Words Used Often In This
document and any changes we make to this document from for reference purposes onl Agreement. The headings are
time to time. y
HOW TO USE YOUR ACCOUNT
"APR" means the correspondi= Annual Percentage Rate. You may obtain credit' in the form of Balance Transfers,
The APR corresponds to the Daily Periodic Rate ("DPR") Cash Advances, and Purchases by using cards, access
which is calculated by dividing the corresponding APR by checks, your account number, or other credit devices.
365.
ay other ppersonlwitith au horation for luse ono this u accccount
pursuant to this Agreement.
Ballan et ?sf rs Cash Advances, a d Puuichasesp thou
further notice in certain instances of your default, as
described in the section titled, Annual Percentage Rates.
"Foreign Transaction" means any transaction made in a
foreign currency (including, for example, online purchases
from foreign merchants).
"Grace Period" means the period of time during a billing
cycle when you will not accrue Periodic Rate Finance
Charges on certain transactions or balances.
"New Balance Total" means the total billed amount as of
the Closing Date of a billing cycle, as shown on our
monthly statement. To determine the New Balance Total,
we start with the total balance at the beginning of the
billing cycle, which is the "Previous Balance." Then we
subtract payments and credits. Then we add Cash
Advances, Balance Transfers, Purchases and Adjustments
and finance charges.
"Pay in Full" or "Paid in Full" means payments and credits
in a billingB?zcycle totaling at least your previous billing
cycle's b et?Ba lance Total. In general, Pay in Full must be
Period. by Payment Due Date in order to get a Grace
"Promotional Offer" means limited time
promotional offers on certain Balance
Advances or Purchases at APRs that are
Standard Rates for those featurea f"P,v,n,nt
time introductory or?pro:
otional Fees") which may bi
adard fees provided in the
"Standard Rate" means the APR(s) normally in effect for
Balance Transfers, Cash Advances, and Purchases.
"We", "us" "our", and "FIACS" means FIA Card Services,
NA., also mown as Bank of America.
"You" and "your" mean each and all of the persons who are
granted, accept or use an account we hold. '`You" and "your"
also mean any other person who has guaranteed payment of
this account, when used in the sections titled Your Contract
With Us, We May. Monitor And Record Telep6ne Call and
Arbitration and Litigation, and when used in each of the
sections relating to payment of this account (e.g., Your
"Balance Transfer" means a transfer of funds to another
creditor initiated by us at your reqquest. A Balance Transfer
Advance. Balance T`ransferrs lioncludetTrransaction Feaes and
adjustments associated with any Balance Transfer.
"Cash Advance" means the use of your account for a loan
obtained:
1. at an automated teller machine ("ATM Cash Advance");
2. by a transfer of funds to a deposit account initiated by
us at your request. C'Direct Deposit"). A ,Direct Deposit
does not include an Overdraft Protection Cash Advance
or a same day online funds transfer;
3. at any financial institution (e.g., to obtain cash, money
orders, wire transfers, or travelers checks), by a same
day online funds transfer to a deposit account, and at
any non-financial institution (to obtain cash) C'Bank
Cash Advance");
4. as part of an Overdraft Protection . Program -- a
transfer of funds to a deposit account pursuant to an
overdraft protection program ("Overdraft Protection
Cash Advance');
5. to buy "Cash Equivalents" (i.e., foreign currency, money
orders or travelers checks from a non-financial
institution, or person to person money transfers, bets,
lottery tickets, casino gaming chips, fines or bail bonds)
with your card;
6. by an access check you sign as drawer C'Check Cash
Advance");
7. for any payment you make to us that is returned to us
unpaid for any reason, including the related finance
charges C'Returned Payment'):
"Cash Advance" includes Transaction Fees and adjustments
associated with any Cash Advance.
"Purchase" means the use of your card
to: or account number
1. buy or lease goods or services;
2. buy wire transfers from a non-financial institution
("Wire Transfer Purchase");
3. make a transaction that is not otherwise a Cash
Advance.
"Purchase" includes Account Fees, as well as Transaction
(continued)
Fees and adjustments associated with any Purchase.
ANNUAL PERCENTAGE RATES
This section provides the Standard Rates, Default Rates and
Promotional 'Offers applicable to your account.
Balance Transfers: The Standard Rate for Balance
Transfer balances is a corresponding ANNUAL
PERCENTAGE RATE of 9.90%(0.02712346 DPR).
Cash Advances: The Standard Rate for Cash Advance
balances is a corresspponding ANNUAL PERCENTAGE
RATE of 24.99%(0.068466% DPR).
Purchases: The Standard Rate for Purchase balances is a
corre ondin ANNUAL PERCENTAGE RATE of
9.90%K0.027K3% DPR).
Default Pricing: We may increase the APRs on all new
and outstanding Balance Transfer Cash Advance, and
Purchase balances up to the Default Rate, without giving
you additional notice, each time you have two "default
re-pricing events" in any twelve rolling consecutive billing
cycles. A default re-pncin event means: (1) you fail to
make any Total Minimum Payment Due by its Payment Due
Date; or (2) your total outstanding balance exceeds your
credit limit at any time in a billing cycle We may elect to
set your APRs for Balance Transfer, Cash Advance and
Purchase balances to different Default Rates. Default Rates
are variable rates calculated using the Variable Default
Rate formula with a margin of up to 23.99 nercentaup
2008 then this Promotional Offer will ap ly to eligible
transactions posting to your account hrough your
statement Closing -Date in February 2009 and this
Promotional Offer will end on your statement Closing Date
in February 2009. If an eligible transaction does not post to
your account by your statement Closing Date in August
2008, then the Promotional Offer will end on your
statement Closing Date in A t 2008. Check Cash
Advances bearing Offer ID HHFiH7MB and Direct
Deposits which get this Promotional Offer will post to your
account as Balance Transfers.
During the time in which you ma make quali
transactions under this Promotional Offer, they will gee
subject to the following Promotional Fees:
Balance Transfers: 3.00% of each such uali?
transaction (Fee: Min. $10.00; Max. $99.00) (F?NANC
CHARGE).
This Promotional Offer may end at any time if there is a
"promotion turn-off event.' A promotion turn-off event
means: (1) that any Total Minimum Pa went Due is not
received by its Payment Due Date; or (2) that your total
outstanding balance exceeds your credit limit on an
statement Closing Date. If a -promotion turn-off event
occurs then this Yromotional Offer will end as of the first
R oft that billing cycle. This means that this Promotional
Rate will not be in effect in that billing cycle.
Promotional Offer ID H6BHHH7MC. The Promotional
ANNUAL ERCENTAGE?RATEr of is 199% 0sspp005452
DPR).
occurs. with each aamtionai default re-pricing event we This Promotional Offer applies to Purchases each at least
will again determine whether there have been two dei`ault $500.00 (each an "eligible transaction" for this Promotional
re-pricing events in the preceding twelve consecutive billing offer).
cycles. All Default Rates will remain in effect until you
make each Total Minimum Payment Due by.its Payment
Due Date and do'
o not exceed your credit limit for six
consecutive billing cycles, starting with the first bil p cycle
after the Default rate is in effect. At that time we wilt lower
the margin for.each of these variable APRs by at least two
Lercentage points. These will be your new variable
Standard Ratea.
Promotional Offers:.
From time to Beal a we 4aymake Promotional Offers on
This Promotional Offer applies to new eligible transactions
beginning on June 9, 2008. If an eligible transaction posts to
yo
Will ur account by August 1, 2008 then this Promotional Offer
apply to ellIp a transactions poat?n¢ to your account
thro uP¢trio your statement Closing Date in January 2009 and
this motional Offer will end on your statement Closing
Date in January 2009. If an eligible transaction does not
to your account by August 1 2008, then the
91
otional Offer will end on August 1, X008.
new ance n ers Cash Advances, and This Promotional Offer may end at an time if there is a
Purchases. When a Promotional Offer ends, its Promotional promotion turn-off event' A promotion turn-off event
Rates will terminate. Any Balance Transfer Cash Advance means: (1) that any Total Minimum Payment Due is not
or Purchase balance subject to that Promotional Offer wilt received by its Payment Due Date; or (Z) that your total
return to its respective Standard Rate or Default Rate as outstanding balance exceeds your credit limit on any
applicable. statement Closing Date. If a romotion turn-off event
occurs then this motional Offer will end as of the first
Check Cash Advances and Direct Deposits are Cash day of that billing cycle. This means that this Promotional
Advances. However if Check Cash Advances or Direct Rate will not be in effect in that billing cycle.
Deposits are identfffed in the Pmmntional (war ac "n,%-*i -
Promotional Offer ID H6BHKH7MD: The Promotional
ANNURate PECERCENTAGE RATE ofs 199%0 0pWS 52?&
DPR).
ends, instead of the Cash Advance Rate. In addition, these This Promotional Offer applies to Balance Transfers Direct
transactions will get the Balance Transfer transaction fee if Deposit Cash Advances and Check Cash Advances hearing
they qualify for the Promotional Offer. tlns Promotional Offer ID (each an "eligible transaction" for
Promotional Offer ID H6BHKH7MB: The Promotional this Promotional Offer).
Rate for this Promotional Offer is a correonding This Promotional Offer applies to new eligible transactions
DAPNRNUAL PERCENTAGE RATE of 1.99% (025452 % beginning on June 13, 2008. If an eligible transaction posts
This Promotional Offer applies to Balance Transfers Direct
Deposit Cash Advances and Check Cash Advances hearing
this Promotional Offer ID (each an "eligible transaction" for
this Promotional Offer).
This Promotional Offer applies to new eligible transactions
beginning on May. 18, 2008. If an eligible transaction posts
to your account by your statement Losing Date in August
u accoun by your statement Closing Date in August
then this Promotional Offer will apply to eligible
fictions posting to ur account through your
vent Closing Date in March 2009 and this Promotional
will end on your statement Closing Date in March
If an eligible transaction does not post to your account
ur statement Closing Date in August 2008, then the
)tional Offer will end on your statement Closing Date
must 2008. Check Cash Advances bearing Offer ID
KH7MD and Direct Deposits which get this
Promotional Offer will post to your account as Balance variable rates is 5.25% and was determined on June 30,
Transfers. 2008.
During the time in which you mayy? ?make qualifying
transactions under this Promotional Offer, they will be
subject to the following Promotional Fees:
Balance Transfers: 3.00% of each such qqualif_yy1i'n
transaction (Fee: Min. $10.00; Max. $99.00) (F'INANC1
CHARGE).
This Promotional Offer maX end at any time if there is a
"promotion turn-off event.' A promotion turn-off event
means: (1) that any Total Minimum Payment Due is not
received by its Payment Due Date; or (2) that your total
outstanding balance exceeds your credit limit on any
statement Closing Date. If a promotion turn-off event
occurs then this Promotional Offer will end as of the first
day of that billing cycle. This means that this Promotional
Rate will not be in effect in that billing cycle.
Promotional Offer ID H6BHKH7MF: The Promotional
ANNUAL ERCENTAGE?RATErofs199% (00054 0
DPR).
This Promotional Offer applies to Balance Transfers Direct
tDhis Promotional Offer ID each an elsgib el dtransaction" fog
this Promotional Offer).
This Promotional Offer applies to new eligible transactions
beginning on July 13, 2008. If an eligible -transaction posts
to our account by your statement Closing_ Date in
September 2008 then this Promotional Offer will apply to
eligible transactions ostmg to your account tbro our
statement Closing Date in A ril 2009 and this Promotional
Offer will end on your statement Closing Date in April
2009. If an eligible transaction does not post to your account
by your statement Closing Date in September 2008 then
the Promotional Offer will end on your statement diosing
Date in Sepgt?ember 2008. Check Cash Advances bearing
Offer ID H6BHKH7MF and Direct Deposits which get this
Promotional Offer will post to your account as Balance
Transfers.
An increase or decrease in the index will cause a
corresponding increase or decrease in your variable rates on
the first day of your billing cycle that begins in the same
month as the determination date. An increase in the index
means that you will pay higher periodic rate finance
charges and have a higher Total Minimum Payment Due. If
The Nall Street Journal does not publish the U.S. Prime
Hate, or i changes a definition of the U.S. Prime Rate,
we may, at our sole discretion, substitute another index.
CALCULATION OF PERIODIC RATE FINANCE
CHARGES
We calculate Periodic Rate Finance Charges by multiplying
each Balance Subject to Finance Charge by its applicable
DPR and that result 'the number ofdays in the billing
Sycle. When Periodic Rate Finance Charges accrue on a
Balance Transfer, Cash Advance or Purchase balance, those
finance chargea become part of that respective Balance
Transfer, Cash Advance, or Purchase balance.
BILLING CYCLE
Your billing cycle ends each month on a Closing Date
determined by us. Each billing cycle begins on the day after
the Closing Date of the previous billing cycle. Each monthly
statement reflects a single billing cycle.
WHEN PERIODIC RATE FINANCE CHARGES BEGIN
inn sr-nnirc
Each new Balance Transfer and Cash Advance begins to
accrue Periodic Rate Finance Charges on its transaction
date. Balance Transfer and Cash Advance balances
remaining from previous billing cycles accrue Periodic Rate
Finance Char s from the first day of the billing cycle. The
transaction date for Check Cash Advances and Balance
Transfers made by check is the date the check is first
deposited or cashed. The transaction date for a Returned
Payment is the date that the corresponding payment posted
to your account.
Unless sub'ect to a Grace Period, each new Purchase beg' s
to accrue periodic Rate Finance Charges on its transaction
date or the first day of the billing cycle, whichever date is
During the time in which you may make later. Unless subject to a Grace Period, Purchase balances
transactions under this Promotional Offer, they will be Fi ance Charom previous brst cycles accrue Periodic Rate
subject to the following Promotional Fees: Sce from the firstay of the billing cycle.
Balance Transfers: 3.00% of each such ng
transaction (Fee: Min. $10.00; Max. $99.00) (&S81
CHARGE).
anis Promotional Offer may end at any time if there is a
"promotion turn-off event.' A promotion turn-off event
means: (1) that any Total Minimum Payment Due is not
received by its Payment Due Date; or (2) that ur total
outstanding balance exceeds your credit limit, on any
statement Closing Date. If a Offer turn-off event
occurs then this Promotional Ofi'er will end as of the first
day of that billing cycle. This means that this promotional
Rate will not be in effect in that billing cycle. However, if a
promotion turn-off event occurs during the billing cycle that
includes August 13, 2008 then this Promotional Offer will
end on the last day of that billing cycle.
VARIABLE RATE INFORMATION
We will use the following variable rate formula for variable
Standard Rates, variable Default Rates and variable
Promotional Rates. All variable rates are calculated by
adding together an index and a margin. For each variable
rate, the applicable margin is disci above in the section
titled, Annual Percentage Rates.
This index is determined on the last business day of each
month ("determination date'? and is the highest U .S. Prime
Rate as published in the "Money Rates" section of The Wall
Street Journal at any time within the immediately
index was determmiin dsThelindex tussed to calcullaatecthese
When a licable, Periodic Rate Finance Charges accrue
daily, and compound daily on new balances, and balances
remaming from previous billing cycles. Periodic Rate
Finance (;barges will continue to accrue even though you
wevlncludethany accrueod but unpaid finance charges in theme
calculation of each Balance Subject to Finance Charge.
Your Payment Due Date will be at least 20 days from your
statement Closing Date.
GRACE PERIOD
You do not have a Grace Period for Balance Transfers or
Cash Advances. You will have a Grace Period on new
Purchases, in a billing cycle in which you Pay in Full from
the day after the Pay in Full date until the end off' that
billing cycle. You will have a Grace Period for an entire
billing cycle on new Purchases and on Purchase balances
remaining from previous billinngg cyyccles if you Pay in Full by
the Payment Due Date in that bfllfn cycle and if during
the previous billing cycle you Paid in Full,
CALCULATION OF BALANCES SUBJECT TO
FINANCE CHARGE
Averse Balance Method (including new Balance
Transfers and new Cash Advances): We calculate
separate Balances Subject to Finance Charge for Balance
Transfers, Cash Advances, and for each Promotional Offer
balance consisting of Balanyyce Transfers or Cash Advances
ciyinzent baillingacyicge; (2acalculatl?ca daily balaneeyfor each
day prior to tale current billing cycle that had a "Pre-Cycle
(continued)
balance" -a Pre-Cycle balance is a Balance Transfer or a
Cash Advance with a transaction date prior to the current
billing cycle but with a posting date within the current
biAinjg cyclge; (3) adding alI the daily balances together; and
(4) dividin the sum of the daily balances by the number of
days in the current billing cycle.
To calculate the daily balance for each day in the current
billing cycle, we take the beginning, balance, add an amount
equal- to the applicable Daily Periodic Rate multiplied by
the revious day's daily balance, sdd new ITilance
Transfers, Cash Advances . and Transaction .. Fees, and
subtract applicable payments and credits. If any daily
balance is tees than zero we treat it as zero.
To calculate a daily balance for each day prior to
current billing cycle that had a Pre-Cycle balance we
the beginning balance attributable solely to a N;-(
balance (which will be zero on the transaction
associated with the first Pre-Cycle balance) add an am
equal to the applicable Daily Periodic Raie multipiie,
the Previous dav's daily alanrp_ ana Gild ,, I-
a pucawe rre-t; le balances, and their related Transaction
ees. We exclu a from this calculation all transactions
posted in previous billing cycles.
Average, Dail Balance Method (including new
Purchases): We calculate separate Balances Subject to
Finance Charge for Purchases and for each Promotional
Offer balance consist' of Purchases by: (1) calculating a
daily balance for eachhhay in the current bbillin cle; (2)
adding all the daily balances t?her; and (3) d vi Me)
sum of the daily balances by the number of days 'i the
current billing cycle.
the
we
day in the current
ice. add an amount
the U.S. dollar amount of each such Cash Advance (Fee:
Min. $10.00).
If you obtain a Check Cash Advance, we will assess a
transaction fee (FINANCE CHARGE) equal to 3.00% of
the U.S. dollar amount of each such Cash Advance (Fee:
Min. $10.00).
If you obtain a Direct Deposit, we will assess a transaction
fee (FINANCE CHARGE) equal to 3.00% of the U.S. dollar
amount of each such Cash Advance (Fee: Min. $10.00).
If you make a Foreign Transaction we will assess a
transaction fee (FINANCE CHARGE) equal to 3.00% of
the U.S. dollar amount of each such Foreign Transaction.
This is in addition to any other applicable transaction fees.
If you obtain an Overdraft Protection Cash Advance, we will
assess a transaction fee (FINANCE. CHARGE eggal to
3.00% of the U.S. dollar amount of each such Cas Advance
(Fee: Min. $10.00).
If you make a Wire Transfer Purchase, we will assess a
transaction fee (FINANCE CHARGE) equal td 3.00% of
the U.S. dollar amount of each such Purchase (Fee: Min.
$10.00).
ACCOUNT FEES: The following fees are assessed as
Purchases in the Billing Cycle in which the fees accrue:
A Late Fee if the Total Minimum Payment Due shown on
your month?l statement is not received by us on or before
its Payment ?ue Date. On the Late Fee transaction date:
• if the total outstandin balance is $100.00 or less,
the Late Fee will be $fS.00;
• if the total outstanding balance is Eel ater than
100.00 but $250.00 or less, the LaFee will be
129.00;
• if the total outstanding balance is eater than
$250.00, the Late Fee will be $39.1
A Returned. Payment Fee of $39.00 if a payment on your
account is returned for insufficient funds or for any other
reason, even if it is paid upon subsequent presentment (if
we elect to re-present the payment).
A Returned Access Check Fee of $39.00 if we return an
access check unpaid for any reason, even if the access check
is paid upon subsequent presentment.
A Copy Fee of $5.00 for each copy of a monthly statement or
sales draft, except that the six most recent monthly
statements and one sales draft will be provided for free.
im- t=race Period new Purchases, new Account Fees, and new
Transaction Fees, and subtract applicable payments and
credits. If any daily balance is less than zero we treat it as
zero. If in the current being cycle you Pay in Full, then on
the day after that Pay in FuK date, we exclude from the
beginning balance new Purchases, new Account Fees and
new Transaction Fees which posted on or before the Play in
Full date.
We include the costs for credit card debt cancellation or
credit insurance purchased through us in calculating the
be &n' Purchase balance for the first day of the billing
cycle after the billing cycle in which such costs are billed.
MINIMUM FINANCE CHARGE
If the total of the Periodic Rate
balances is less than $1.50, then
CHARGE of $1.50 will be assessed
any Periodic Rate Finance Charge.
Finance C ge.s for all An Abandoned Property Fee equal to any costs incurred by
a minimumxFINANCE us for complying with state abandoned property laws, unless
on the account in lieu of prohibitedlly applicable law.
TRANSACTION FEE FINANCE CHARGES
We will assess the following Transaction Fees to your
Account in the same balance category to which the
transaction is posted:
If you obtain an ATM Cash Advance, we will assess a
transaction fee (FINANCE CHARGE) equal to 3.00% of
the U.S. dollar amount of each such Cash Advance (Fee:
Min. $10.00).
If you obtain a Balance Transfer we will assess a
transaction fee (FINANCE CHARG1k) equal to 3.00% of
the U.S. dollar amount of each such Balance Transfer (Fee:
Min. $10.00).
If you obtain a Bank Cash Advance, we will assess a
transaction fee (FINANCE CHARGE) equal to 3.00% of
the U.S. dollar amount of each such Cash Advance (Fee:
Min. $10.00).
ttransactiont ee (FINANCEc?wvateCHARGE) equal will assess 0 of
OVERDRAFT PROTECTION
If your checking account with
this account, this overdraft F
funds to be transferred Cove
from this account into your
with Bank of America (
transactions occur on your che(
or other debits, that if paid
account to be overdrawn
Overdraft protection transfers
to cover checking account
transfers _are processed after
unded• to
account in
Mt is oven
u to your
t?Pe overdr
account ha
item for $1
cause your
protection
of America is linked to
:ion feature will allow
(a25 if you opened
or Idaho: $50 if your
sty Banff increment
dices of who initiated
ple, if your checking
check or other debit
, which if paid would
rdrawn, an overdraft
made to your checking
ice oz pl.uu anti a
sented for payment
of $200 twill beove
account and an Overdraft Protection Cash Advance of $200
will post to this account. The amount of available credit on
this account must be sufficient to cover the total amount of
overdraft transactions (received by Bank of America that
day) rounded to the next $100 increment (but excluding any
overdraft protection fee)- otherwise one or more of the
overdraft transactions for that day will be rejected.
However, if the available credit on this account is greater
than the overdraft transaction amount, but the available
credit is insufficient for the overdraft transaction amount to
be rounded to the next $100 increment, then the amount of
the overdraft transaction will be rounded to the highest
whole dollar amount of your available credit. (And in such
an event, the accrued finance charges may result in an
Overlimit Fee.) We may permit or refuse to permit an
overdraft protection transfer that would cause you to exceed
the credit limit on this account; but if we permit it, you may
be assessed an Overlimit Fee during the billing cycle in
which the transfer occurs. This overdraft protection feature
will automatically be cancelled if this account is closed by
either you or us, or at any time upon your request. Your
overdraft transactions remain subject to the terms of your
checking account with Bank Of America, any related
enrollment agreement, and this Agreement.
SIGN YOUR CARD
You should sign your card before you use it.
WE MAY MONITOR AND RECORD TELEPHONE
CALLS
You consent to and authorize Bank of America, any of its
affiliates, or its marketing associates to monitor and/or
record any, of your telephone conversations with our
representatives or the representatives of any of those
companies. Where you have provided a cell phone number
directly to us, or placed a cell phone call to us you consent
and agree to accept collection calls to your cell hone from
us. For an telephone or cell phone calls we place to you,
you consent and agree that those calls may be automatically
dialed and/or use recorded messages-
SHAARRING DORM TION NCIES; COLLECTING AND
You authorize us to collect information about you in order
to conduct our business and deliver the top quality service
you expect, including information we receive about you
information we receive from third parties such as credii
re porting a1Tncies and information about your transactions
with ue and other companies. You authorize us to share
such information about you or your account with our
affiliates and others.. You may have the right to opt out of
some information sharing. For more details, please refer to
our Privacy Policy.
If you believe we have furnished inaccurate or incomplete
information about you or your account to a credit reports?
ncy, write to us at: F IA Card Services N.A., Cred?f
eportm encies P.O. Box 17054, Wilmington, DE
19884-7 tease include your name, address, home phone
number, and account number, and explain what you believe
is inaccurate or incomplete.
PURPOSES FOR USING YOUR ACCOUNT
You may use your account for personal, family, or household
purposes: You may not use your account for business or
commercial purposes. You may not use a Balance Transfer,
or Check Cash Advance, or any other Cash Advance, to
make a payment on this or any other credit account with us
or our affiliates. You may not use or permit your account to
be used to make any illegal transaction. You will only use
your account for transactions that are legal where you
conduct them. For example, Internet gambling transactions
may be illegal in your state. Display o a payment card logo
by an online merchant does not mean that an Internet
transaction is legal where you conduct it. We may charge
your account for such transactions. We will not be liable if
you engage in an illegal transaction. We may deny
authorization of any transactions identified as Internet
gambling.
PERSONS USING YOUR ACCOUNT
If you permit any person to use your card, access checks,
account number, or other credit device with the
authorization to obtain credit on your account, you may be
liable for all transactions made by that person including
transactions for which you may not have intended to be
liable, even if the amount of those transactions causes your
credit limit to be exceeded. Authorized users of this account
may have the same access to information about the account
and its users as the account holders. We may send account
materials (cards, statements and notices) to any liable
arty, and that person will be responsible for delive
hose materials to the other liable parties and authorized
users. Notice to any of you will be considered notice to all of
ypou. You may allow authorized users on your account in the
following ways: (1) b notifying us that you want someone
added to your accoun.1 as an authorized user- (2) by lending
your card or account number to another; or (b) by any other
ways in which you would be legally considered to have
allowed another to use our account or to be legsy
prevented from denying that you did so. You must think
carefully before you allow anyone to become. an authorized
user. By doing so, you authorize the person to use your
account to the same extent you can including but not
limited to making any purchases, casi advances, balance
transfers and allwing others to use your account. Your
account does not permit you to limit the nature or amount
of authority you give to any authorized user and you will
not attempt to do so. An authorized user's authority will
continue until you both notify us that you are termmating
the authority and you physically retrieve the card. If you
cannot retrieve the card, you will remain liable for any
transactions that we cannot prevent after you notify us.
YOUR PROMISE TO PAY
You promise to pay us the amounts of all credit you obtain,
which includes all Purchases, Cash Advances, and Balance
Transfers. You also promise to Fay us all the amounts of
finance charges, fees,. and any other transactions we charge
to your account. If a bank branch or office sponsors your
account, you promise to pay it any unpaid account balance
it pays us within 30 days.
PAYMENTS ON YOUR ACCOUNT
You must pay each month at least the Total Minimum
Payment Due shown on your monthly statement by its
Payment Due Date. Your Payment Due Date may vary from
month to month. Payments must conform to the
requirements set out on that monthly statement; these
requirements may vary without prior notice. You may pay
the entire amount you owe us at any time. Payments made
in any billing cycle that are greater than the Total
Minimum Payment Due will not affect?your obligation to
make the next Total Minimum Payment Due. If you overpay
or if there is a credit balance on your account, we will not
pay interest on such amounts. We will reject payments that
are not drawn in U.S. dollars andose drawn on a
financial institution located outside of the United States.
We reserve the right to reject any payment if your account
has a credit balance as of the. day we receive that payment.
Generally, credits to your account, such as those generated
by merchants or by person-to-person money transfers are
not treated as payments and will not reduce your Ntal
Minimum Payment Due.
ACH PAYMENTS
We process most payment checks electronically. We use the
information on your check to create an electronic funds
transfer. Each time you send a check you authorize a
One-time electronic funds transfer. You also authorize us to
pprocess your check as a check or paper draft, as necessary.
finds may be withdrawn from your account as soon as the
same day we receive your payment. You will not receive
your cancelled check because we are required to destroy it.
We will retain an electronic copy. For more information or
to atop the conversion of your checks into electronic funds
transfers, call us at the phone number listed on the front of
your monthl statement. You may also write to us at: P.O.
Box 15019, Wilmington, DE 19850-5019.
TOTAL MINIMUM PAYMENT DUE
You may pay your total outstanding balance at any time.
I
J
..continued)
Each billinX cycle, you must pay at least the Total Minimum
Payment ue shown on your monthly statement by its
Payment Due Date. The Total Minimum Payment Due is
the sum of all past due amounts plus the Current Payment.
The Current Payment for each billing cycle includes three
amounts: (1) 1.00% of your balance (your New Balance Total
except for any new Periodic Rate Finance Charges, and Late
Fee), and (2) new Periodic Rate Finance Charges, and (3)
new Late Fee. Generally, the lowest it will be is $15.00. We
round the payment amount down to the nearest dollar. If a
payment is credited to your account but is returned. unpaid
in a later billing cycle we will recalculate the Total
Minimum PayE L Due for the billing cycle in which the
payment was originally credited.
WHEN YOUR PAYMENT WILL BE CREDITED TO
YOUR ACCOUNT
We credit payments as of the date received, if the payment
is: (1) received by 5 p.m. Eastern time; (2) received at the
address shown W the upper left-hand corner of the front of
your monthly statement; (3) paid with a check drawn in
U.S. dollars on a U.S. financial institution or a U.S. dollar
mone order; and (4) sent in the return envelope with onl
the lop portion of your statement accompanying iT
Payments received after 5 m. Eastern time on any day
including the Payment Due -Date, but that otherwise meet
the above requirements, will be credited as of the next day.
Credit for any other payments may be delayed up to five
days.
HOW WE ALLOCATE YOUR PAYMENTS
We will allocate your payments in the manner we
determine. In most instances, we will allocate your
payments to balances (including transactions made after
your latest statement) with lower APRs before balances
with higher APRs. This will result in balances with lower
APRs (such as new balances with promotional APR offers)
being paid before any other existing-balances.
PROMISE TO PAY APPLIES TO ALL PERSONS
All persons who initially or subsequen re
tly quest , accept,
guarantee or use the account are indually and together
responsible for any total
e outatandu balance. If you and
y total
on. or more ppeersons are respo nsi ble to pay an
Lm&A nbancewe may refuse to release ny oiabil until ail of the cardsaccess checks nd otcdces outstanding under the account ve been
reed to us and you reppay ue the fatal outstanding
balance owed to us at any dime under the terms of this
Agreement.
DEFAULT
You will be in default of this Agreement if (1) you fail to
make any required Total Minimum Payment Due b its
Payment Due Date; (2) your total outet dir balance
exceeds your credit hmit; or 03) you fail to abiule by any
other term of this Agreement. pour failure to exercise any of
our rights when you default does not mean that we are
unable to exercise those rights upon later default.
WHEN WE MAY RE%UIRE IMMEDIATE REPAYMENT
If you are in default, en in addition to our other remedies
under this Agreement, we can require immediate payment
of your total outstanding balance and, unless prohibited by
applicable law and except as otherwise provided under the
Arbitration and Litigation section of this Agreement, we can
also require you to pay the costa we incur in any collection
proceeding, as well as reasonable attorneys' fees if we refer
your account for collection to an attorney who is not our
OTHER PAYMENT TERMS
We can accept late payments, partial Payments, or
payments with any restrictive writing withou losing any of
our rights under this Agreement. This means that no
payment, including those marked with "paid in full" or with
any other restrictive words, shall operate as an accord and
satisfaction without the prior written approval of one of our
senior officers. You may not use a postdated check to make
a payment. If you do postdate a payment check, we may
elect to honor it upon presentment or return it uncredited
to the person that presented it, without in either case
waiting i'or the date shown on the check. We are not liable
to you for any loss or expense incurred by you arising out of
the action we elect to take.
PAYMENT HOLIDAYS AND REDUCED PAYMENT
OFFERS
We may allow you, from time to time, to omit a monthly
payment or make a reduced payment. We will notify you.
when these options are available. If you omit a payment or
make a reduced payment, finance charges applicable fees,
and other regular transactions, if any, will accrue on your
account balances in accordance with this Agreement. The
reduced payment amount may be less than your finance
charges. You must make the reduced payymment on time to
avoid a late fee. You must resume Then your regular
Total Minimum Payment Due each month following a
payment holiday or reduced payment offer.
WHAT WE MAY DO IF YOU ATTEMPT TO EXCEED
YOUR CREDIT LIMIT
The total outstanding balance on your account plus
authorizations at an time must not be more than our
credit limit. If you attempt a transaction which resulla in
your total outstandm balance (plus authorizations)
exceedin& your credit Qt, we ni .. (1) permit the
transaction without raising your credit limit; (2) permit the
transaction and treat the amount of the transaction that is
more than the credit limit as immediately due; or (3) refuse
to permit the transaction.
If we refuse to permit the transaction, we may advise the
person who attempted the, transaction that it has been
refused. If we refuse to permit a Check Cash Advance or
Balance Transfer we may do so by advising the person
resentm? the Check Cash Advance or Balance Transfer
chat credit has been refused that there are insufficient
funds to pa the Check Cash advance or Balance Transfer,
or in any other manner.
If we have previously permitted you to exceed your credit
limit, it does not mean that we will permit you to exceed
your credit limit again. If we decide to permit you to exceed
your credit limit which could trigger a promotion turn-off
thin tAgr we e may Zso charge an Over7fmit Fee as provided in
WE MAY AMEND THIS AGREEMENT
We may amend this Agreement at any time. We may amend
it by adding- deleting, or changing provisions of this
ement. e may increase or decrease any or all of your
Rs. We may increase any or all of your APRs to rates
which exceed the Default Rate. When we amend this
Agreement we_ will comply with the auulicable notice
uuciucuoa ?a LuumaL nau LLelaware law znaz are
at hat time. The amended Agreement (including ai
rate or other higher charges or fees) will annly to
u-ne amendmenti pecame enective. If an amendment gives
you the opportunity to reject the change, and if you reject
the change in the manner provided in such amendment, we
may terminate your right to receive credit and may ask you
to return all credit devices as a condition of your refection.
We may replace your card with another card at any tune.
WE MAY SUSPEND OR CLOSE YOUR ACCOUNT
We may suspend or close your account or otherwise
terminate your right to use your account. We may do this at
any time and far any reason. Your ob ' tions under this
Agreement continue even after we have done this. You must
destroy all cards, access checks or other credit devices on
the account when we request.
YOU MAY CLOSE YOUR ACCOUNT
You may close your account by notifying us in writing or by
telephone, and destroying all cards, access checks or other
credit devices on the account. Your obligations under this
Agreement continue even after you have done this.
TRANSACTIONS AFTER YOUR ACCOUNT IS
CLOSED
When your account is closed, you must contact anyone
authorized to charge transactions to your account, such as
internet service providers, health clubs or insurance
companies. These transactions may continue to be charged
to your account until you change the billing. Also, if we
believe you have authorized a transaction or are attemptinto use your account after you have requested to close the-
account, we may allow the transaction to be charged to your
account.
REFUSAL TO HONOR YOUR ACCOUNT
We are not liable for any refusal to honor your account.
This can include a refusal to honor your card or account
number or any check written on your account. We are not
liable for any retention of your card by us, any other
financial institution, or any provider of goods or services.
HOW YOU MAY STOP PAYMENT ON AN ACCESS
CHECK
You may request a. stop payment on an access check b
providing us with the access check number, dollar amour
and payee exactly as they appear on the access check Oral
and written stop pa ent requests on an access check are
effective for six months from the day that we place the stop
payment.
YOU MAY NOT POSTDATE AN ACCESS CHECK
You ma not issue a postdated access check on your
account. If you do postdate an access check, we may elect to
honor it upon . resentment or return it unpaid to the person
that presented it to us for payment, without in either case
waiting for the date shown on the access check. We are not
liable to you for any loss or expense incurred by you arising
out of the action we elect to take.
TRANSACTIONS MADE IN FOREIGN CURRENCIES
If you make a transaction in a foreign currency, the
transaction will be converted by. Visa International or
MasterCard International, depending ' on which card you
use, into a U.S. dollar amount in accordance with the
operating regulations or conversion procedures. in effect at
the time the transaction is processed. Currently, those
regulations and procedures provide that the currency
conversion rate to be used is either (1) a wholesale market
rate or (2) a government-mandated rate in effect one day
prior to the processing date. The currency conversion rate in
effect on the processing date may differ from the rate in
effect on the transaction date or posting date.
We may offer you certain. benefits and services with your
account. An benefits or services are not a part of this
Agreement, but are subject to the terms and restrictions
outlined in the benefits brochure and other official
documents provided to you from time to time by or on
behalf of Bank of America. While any benefits or services
described in the previous sentence are not a part of this
Agreement, any claim dispute related to any such benefit
or service ;hall be subor ject to the Arbitration and Litigation
section of this Agreement. We may a ust, add, or delete
benefits and services at any time and wiihout notice to you.
WE MAY SELL YOUR ACCOUNT
We may at any time, and without notice to you, sell, assign
or transfer your account, an sums due on your account,
this A eement, or our rights or obligations under your
accoun or this Agreement to any person or entity. The
person or entity to whom we make any, such sale,
as nt or transfer shall be entitled to all of our rights
an or obligations under this Agreement, to the extent aold,
assigned or transferred.
YOU MUST NOTIFY US WHEN YOU CHANGE YOUR
ADDRESS
We strive to keep accurate records for your benefit and
ours. The post off ce and others may notify us of a change to
your address. When you change your address, you must
notify us promptly of your new address.
WHAT LAW APPLIES
This Agreement is made in Delaware and we extend credit
to you from Delaware. This Agreement is governed by the
laws of the State of Delaware (without regard to its conflict It,
of laws principles) and by any applicable federal laws.
THE PROVISIONS OF THIS AGREEMENT ARE
SEVERABLE
If any provision of this Agreement is found to be invalid, the
remaining provisions wiI continue to be effective.
OUR RIGHTS CONTINUE
Our failure or delay in exercising any of our rights under
this Agreement does not mean that we are unable to
exercise those rights later.
UNAUTHORIZED USE OF YOUR CARD
Please notify us immediately of the loss, theft or possible
unauthorized use of your account at 1.800.789.6101.
ARBITRATION AND LITIGATION
This Arbitration and Litigation provision applies to you
unless you were given he opportunity to reject the
Arbitration and Litigation provisions and you did so reject
them in the manner and timeframe required. If you did
reject effectively such a provision, you agreed that any
litigation brought by you against us regarding this account
or this Agreement s all be brought in a court located in the
State of Delaware.
Any claim or dispute ("Claim") by either you or us against
the other, or agau?st the employees, agents or assigns of the
other, arising from or relating in any way to this Agreement
or any prior Agreement or your account (whether. under a
statute, in contract, tort, or otherwise and whether for
money damages, penalties or declaratory or equitable relief),
shall, upon election by either you or us, be resolved by
binding arbitration. The arbitrator shall resolve any Claims,
including the applicability of this Arbitration and Litigation
Section or the validio of the entire Agreement or an rior
Agreement, exceepptf any Claim chalI'en ' the vahydipty of
the Class Action-Waiver, which shall be deer led by a court.
In addition, we will not choose to arbitrate an individual
Claim that you bring against us in small claims court or an
equivalent, court, if any. But if that Claim is transferred,
removed or appealed to a different court, we then have the
right to choose arbitration.
Arbitration shall take place before a single arbitrator and
on an individual basis without resort to any form of class
action. Arbitration ma be selected at any time unless a
judgment has been rendered or the other party would suffer
substantial prejudice by the delay in demanding arbitration.
The arbitration shall be conducted by the National
Arbitration Forum CNAF"), under the Code of Procedure in
effect at the time the Claim is filed. Rules and forms of the
National Arbitration Forum may be obtained and Claims
may be filed at any National Arbitration Forum office,
www.arb-forumcom, or P.O. Box 50191, Minneapoolis,
Minnesota 55405, telephone 1-800-474-2371. If the NAP is
unable or unwillin to act as arbitrator, we may substitute
written re nest, we wit! advance any arbitration 111mg tee,
administrative and hearing fees which ou are required to
pay to pursue a Claim in arbitration. e arbitrator will
decide who will be ultimately responsible for aymg those
fees. If u file a claim against us, in no even will you be
required to reimburse us for any arbitration filing,
administrative or hearing fees in an amount greater than
what your court costs would have been if the Claim had
been resolved in a state court with jurisdiction.
Any arbitration hearing at which you appear will take place
within the federal judicial district that includes your billing
address at the time the Claim is filed. This arbitration
agreement is made pursuant to a transaction involving
interstate commerce and shall be overned by the Federal
Arbitration Act, 9 U-S.C. §§ 1-16 ''FAA"). Judgment upon
any arbitration award may be entered in any court having
(continued)
? uriadiction. The arbitrator shall follow existing substantive
aw to the extent consistent with the FAA and applicable
statutes of limitations and shall honor any claims or
privile a recognized by law. If any party requests, the
arbitraor write an opinion containing the reasons for
the award.
No Claim submitted to arbitration is heard by, a 'ury or may
be brought as a class action or as a privag attorney
general. You do not have the right to act as a class
representative or participate as a member of a class of
claimants with respect to any Claim submitted to
arbitration (Class Action Waiver). The parties to this
Agreement acknowledge that the Class Action Waiver is
material and essential to the arbitration of any disputes
between the parties and is nonseverable from this
agreement to arbitrate Claims. If the Class Action Waiver is
limited, voided or found unenforceable, then the parties'
agreement to arbitrate (except for this sentence) shall be
null and void with respect to such proceeding, subject to the
right to appeal the limitation or invalidation of the Class
Action Waiver. The Parties acknowledge and agree that
under no circumstances will a class action be
arbitrated.
This Arbitration and Litigation Section applies to all Claims
now in existence or that may arise in the future. This
Arbitration and Litigation Section shall survive the
termination of your account with us as well as any
voluntary ?ayment of the debt in full by you, any
bankrup cy y you or sale of the debt by us_
For the purposes of this Arbitration and Litigation Section,
"we" and "us" means FIA Card Services, NIL, its parent,
subsidiaries affiliates, licensees, predecessors successors,
assigns, ana any purchaser of your account, ;nia all of their
officers directors employees, "agents and assigns or any and
all of imam. Additionally, we or us" shall mean any third
party roviding benefits services, or products in connection
with f1he account (including but not limited to credit
bureaus, merchants that accept an credit device issued
under the account, rewards or enrollment services, credit
insurance companies, debt collectors and all of their officers
directors, employees and agents) if, and only if, such a third
party is named by you as a co-det?endant in any Claim you
assert against us.
automatically from your savings or checking account with
us, you can stop the payment on any amount you think is
wrong. To stop the payment your letter must reach us three
business days before the automatic payment is scheduled to
occur.
Your Rights and Our Responsibilities After We
Receive Your Written Notice: We must acknowledge your
letter within 30 days, unless we have corrected the error by
then. Within 90 days, we must either correct the error or
explain why we believe the bill was correct.
After we receive your letter, we cannot try to collect any
amount you question or report you as delinquent. We can
continue to bill you for the amount you question, including
finance charges, and we can ap ly any-
ny unpaid amount
against your credit limit. You do not have to pay any
qque??stioned amount while we are investigating, but you are
sill obligated to pay the parts of your bill that are not in
question.
If we fund that we made a mistake on your bill, you will not
have to pps?y any _fmance charges related to any questioned
amount. If we did not make a mistake, you may have to pa
finance charges, and ou will have to make up any missed
payments on the questioned amount. In either case, we will
send you a statement of the amount you owe and the date
that it is due.
If you fail to pay the amount that we think you owe, we
may report you as delinquent. However, if our explanation
does not satisfy you and you write to us within twenty-five
(25) . days telling us that you still refuse to pay, we must tell
anyone we report you to that you have a question about
your bill, and we must tell you the name of anyone we
report you to. We must tell anyone we report you to that
the matter has been settled between us when it finally is.
If we do not follow these rules, we cannot collect the first
$50 of the questioned amount, even if your bill was correct.
Special Rule for Credit Card Purchases: If you have a
problem with the quality of the property or services that
you purchased with a credit card, and you have tried in
good faith to correct the problem with the merchant, you
may have the right not topay the remaining amount due on
the property or services. There are two limitations on this
right
(1) You must have made the purchase in pour home state
or, if not within your home state, within 100 miles of your
current mailing address; and
(2) The purchase price must have been more than $50.
These limitations do not apply if we own or operate the
merchant, or if we mailed you the advertisement for the
property or services.
YOUR BILLING RIGHTS 02007 Bank of America Corporation. All rights reserved.
Keep This Notice for Future Use:This notice contains
important information about your rights and our
responsibilities under the Fair Credit Billing Act.
Notify Us in Case of Errors or Questions About Your
Bill: you think your bill is wrong, or if you used more
information about a transaction on your bill, write us on a
separate sheet (or use a cop of the form provided on your
bill) at Bank of America 'Corporation, F.O. Box 15026,
Wilmington, DE 19850. Write to us as soon as possible. Do
not send the notice on or with your payment. We must hear
from you no later than 60 days after we sent you the first
bill on which the transaction or error appeared. You can
telephone us, but doing so will not reserve your rights. In
your letter, give us the following information: (1) your name
and account number; (2) the do tar amount of the suspected
error. (3) the posting date of the transaction in question;
and (4 a description of the error and an explanation, if you
can, oil why you believe there is an error. If you need more
information, describe the item you are not sure about.
If you have authorized us to pay your credit card bill
VERIFICATION
JESSICA: SNOD BASS
I, , hereby depose and state that:
The language of the foregoing document is that of counsel and not necessarily my
own; however, I have read the foregoing document and the factual information
contained therein is true and correct to the best of my personal knowledge.
I am the Authorized Representative and a duly authorized representative of the
plaintiff;
The factual allegations set forth in the foregoing pleading are true and correct to the
best of my knowledge, information and belief, and they are that NATALIE P.
KEANE owes the balance of 5 6? . 73.74 to CACH, LLC on previously submitted
invoices, which balance is due and unpaid as of the date of the execution of this
Verification.
I am aware that if any of the foregoing is willfully false, I am subject to punishment.
I understand that false statements made herein are subject to the penalties relating to
unsworn falsification to authorities.
By:
Dated: F E 6 0 5 2009
PA 5.15.08
FILSD-OffiCE
OF THE PROTHMTARP
2009 APR -3 AM If: 16
4 OUNN
7 ?. Sb
.? 3) F z-
Sheriffs Office of Cumberland County
R Thomas Kline attic et cumber, Edward L Schorpp
Sheri 4,6.% 4444 Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy {tcE OF THE SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/29/2009 01:30 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April
29, 2009 at 1330 hours, she served a true copy of the within Complaint and Notice, upon the within names
defendant, to wit: Natalie P. Keane, by making known unto Tim Keane, husband of defendant at 79
Ashton Street, Carlisle, Cumberland County, Pennsylvania, 17015, its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $32.50
April 30, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
*WaNjauL
Deputy Sheriff
2009-2093
CACH, LLC v Natalie Keane
1 .: Tr y L i
" Cbj {
Harrison Ross Byck, Esq., P.C.
Attorney I.D. No. 61511
229 Plaza Blvd., Suite 112
Morrisville, PA 19067
1-888-275-6399// (215) 428-0666
CACH, LLC.
Plaintiff(s),
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2009-02093
NATALIE P KEANE
PRAECIPE TO ENTER
Defendant(s). ) JUDGMENT BY DEFAULT
TO THE PROTHONOTARY:
Please enter a Default Judgment in favor of plaintiff, CACH, LLC., and against the defendant(s),
NATALIE P KEANE, for failure to answer or otherwise respond to the Complaint in Civil Action.
The Complaint was served upon the defendant(s) on Apri129, 2009. A copy of the proof of
service is attached hereto as Exhibit "A".
A copy of the Notice of Intention to take Default mailed to defendant(s) NATALIE P KEANE by
regular United States mail, postage paid, on June 19, 2009, is attached hereto as Exhibit "B".
Assess damages in the amount of $ 9614.95 as follows: [a] $ 5673.74 principal being sought in the
Complaint; [b] and $ 2806.46 interest being sought in the Complaint; [c] and reasonable attorney's fees of
$1134.75, or $150.00 per hour, [d] and Court Costs of $ 0.00, [e] and Costs of Service of $0.00.
Date: June 30, 2009
By:
Allan C. Smith, Esq.
Attorney I.D. No. 204756
Sheriff s Office of Cumberland County
R Thomas Kline , Qtititr of ~uui6rrh~i Edward L Schorpp
Sheriff 4 Solicitor
. ~
Ronny R Anderson Jody S Smith
Chief Deputy ~~==ice aF r"= =`vRi~F Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/29/2009 01:30 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April
29, 2009 at 1330 hours, she served a true copy of the within Complaint and Notice, upon the within namec
defendant, to wit: Natalie P. Keane, by making known unto Tim Keane, husband of defendant at 79
Ashton Street, Carlisle, Cumberland County, Pennsylvania, 17015, its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $32.50
April 30, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
r, '
W
Dep ty Sheriff
2009-2093
CACH, LLC v Natalie Keane
Harrison Ross Byck, Esq., P.C.
Attorney I.D. 61511
229 Plaza Blvd., Suite 112
Morrisville, PA 19067
1-888-275-6399// (215) 428-0666
Attorney for Plaintiff
CACH, LLC.
vs.
NATALIE P KEANE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff, )
NO: 2009-02093
Defendant(s).
CERTIFICATE OF SERVICE OF
NOTICE OF INTENT TO FILE
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
I, ALLAN C. SMITH, ESQ., of full age, certify that I mailed a copy of the annexed NOTICE OF
INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT upon defendant NATALIE P
KEANE by United States mail, postage prepaid and certified mail, on June 19, 2009 at his/her last
address of:
110 E COUNTRYSIDE DR
BOILING SPRINGS, PA 17007
Date: June 30, 2009
By:
Allan C. Smith, Esq.
Attorney I.D. No. 204756
Harrison R. Byck, Esq., P.C.
Attorney I.D. No. 61511
229 Plaza Blvd., Suite 112
Morrisville, PA 19067
1-888-275-6399//(215)428-0666
Attorney for the Plaintiff
CACH, LLC. ) COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff, )
vs. ) No.: 2009-02093
NATALIE P KEANE ) NOTICE OF INTENT TO
FILE PRAECIPE TO ENTER
JUDGMENT BY DEFAULT
TO:
NATALIE P KEANE
79 ASHTON RD.
CARLISLE, PA 17015
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN
TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CAN NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
PENNSYLVANIA LAWYER REFERAL SERVICE
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013.
(717) 240-6200
Dated: June 19, 2009
Harrison Ross Byck, Esq., P.C.
Attorney I.D. No. 61511
229 Plaza Blvd.
Suite 112
Morrisville, PA 19067
1-888-275-6399 // (215) 428-0666
Attorney for Plaintiff
CACH, LLC.
Plaintiff,
vs.
NATALIE P KEANE
Defendant(s).
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2009-02093
CERTIFICATION OF NON-MILITARY SERVICE
I, ALLAN C. SMITH, ESQ. of full age, certifies as follows:
1. I am the plaintiff s attorney herein, and have sufficient knowledge of the facts and am
fully authorized to make this Certification;
2. My information is that the defendant is NATALIE P KEANE.
3. Our latest information is that the defendant is employed at UNKNOWN.
3. To the best of my information and belief, the Defendant is not a member of the
military services of the United States of its allies or otherwise within the provisions of the
Soldiers' and Sailors' Relief Act of 1940, as amended, and as stated in the attached
Department of Defense Manpower Data Center reports.
5. This certification is taken subject to the penalties of 18 PaCSA 4904 relating to unsworn
falsification to authorities.
Date: June 30, 2009
By
Allan C. Smith, Esq.
Attorney I.D. No. 204756
Request for Military Status
Department of Defense Manpower Data Center
r',',~+i' ~%~ ,; t
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Pag
JIJN-30-2009 08:58:42
~ Last Name First/Middle Begin Date Active Duty Status Service/Agency
KEANE NATALIE P Based on the information you have furnished, the DMDC does not possess any information
indicating that the individual is currently on active duty.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information
that you provided, the above is the current status of the individual as to all branches of the Military.
rho r~ ,~,..,~,_.a~.-
Mary M. Snavely-Dixon, Director
Department of Defense -Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense
Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military
medical care and other eligibility systems.
The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§
501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands
of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced
a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any
manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the
"defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this
additional Military Service verification, provisions of the SCRA may be invoked against you.
If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can
submit your request again at this Web site and we will provide a new certificate for that query.
This response reflects current active duty status only. For historical information, please contact the Military Service SCRA
points-of-contact.
See: http //www.defenselink.miUfaq/pis/PC09SLDR.html
WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID: BWHDSWTAAYW
https://www. dmdc. osd.miUscra/owa/scra.prc_Select
6/30/2009
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Harrison Ross Byck, Esq., P.C.
Attorney I.D. 61511
229 Plaza Blvd.
Suite 112
Morrisville, PA 19067
1-888-275-639911(215) 428-0666
Attorney for Plaintiff
CACH, LLC.
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 2009-02093
vs.
NATALIE P KEANE
Defendant(s).
To: NATALIE P KEANE
110 E COUNTRYSIDE DR
BOILING SPRINGS, PA 17007
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below:
By:
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X Judgment by Default
_ Money Judgment
_ Judgment in Replevin
_ Judgment for Possession
_ Judgment on Award of Arbitration
Judgment on Verdict
_ .Judgment on Court Verdict
If you have any questions concerning the above, please contact:
ATTORNEY: HARRISON ROSS BYCK, Esquire at 215-428-0666 or 1-888-275-6399
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-2093 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CACH, LLC. Plaintiff (s)
From NATALIE P. KEANE, 79 ASHTON STREET, CARLISLE, PA 17015
(1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL
PERSONAL PROPERTY. HOWEVER, PURSUANT TO PA RCP 3109, PLAINTIFF
DIRECTS SHERIFF AT THE TIME OF THE PERSONAL PROPERTY LEVY, TO
PHYSICALLY IMPOUND ANY AND ALL COMPUTERS, LAPTOPS, PERSONAL TABLET
COMPUTERSS, IPADS, IPODS, SMARTPHONES, CELLPHONES AND BLACKBERRY
DEVICES FOUND IN AND ON THE PREMISES.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$9,614.95
Interest
Atty's Comm %
Atty Paid $246.35
Plaintiff Paid
Date: MAY 21, 2012
(Seal)
L.L. $.50
Due Prothy $2.25
Other Costs
1
avid D. Buell, Prothonotary
By:
Deputy
REQUESTING PARTY:
Name ; CORRYN KRONNAGEL, ESQUIRE
Address: 1276 VETERANS HIGHWAY, SUITE E-1
BRISTOL, PA 19007
Attorney for: PLAINTIFF
Telephone: 215-428-0666
Supreme Court ID No.
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
CACH, LLC.
4340 S. MONACO STREET, 2ND FLOOR
DENVER, COLORADO 80237
Plaintiff(s),
VS.
NATALIE P KEANE
79 ASHTON ST 5
CARLISLE, PA 1701
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No.: 2009-02093
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
ISSUE and INDEX WRIT OF EXECUTION IN THE ABOVE MATTER,
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(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania,
(2) against NANlI.IE P KEANE Defendant(s); ANY AND ALL PERSONAL PROPERTY
TO BE LEVIED AT:
(3) and against
$ 9,614.95
as a lis pendens against the real property of the defendant(s) in the name of the
Garnishee(s) as follows: (Specifically describe property to be levied upon by Sheriff)
(4) Amount Due
Interest from
TOTAL
Garnishee(s);
plus costs.
onnagel, Esq.
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DATE: May 12, 2012
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Anderson
.y S Smith
.nief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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Cach, LLC Case Number
vs.
Natalie P. Keane 2009-2093
SHERIFF'S RETURN OF SERVICE
06/13/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Natalie P. Keane, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Writ of Execution as "Not Found" at 79 Ashton
Street, Carlisle, PA 17015. ,
Per homeowner Gary Brown, he does not know defendant but stated that she lived there prior to him
buying the home 3 years ago. Mr. Brown stated he believes the defendant is living in Maine.
06/14/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as STAYED. Defendant not found at address provided.
SHERIFF COST: $52.79 SO ANSWERS,
June 14, 2012 RON R ANDERSON, SHERIFF
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