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HomeMy WebLinkAbout09-4764IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH. LLC. VS. NO: O9-q7&4 Ciy;c-lerm JAMES E GILLILAND 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.: U l ' ! / to JAMES E GILLILAND 2007 DOUGLAS DR CARLISLE, PA 17013 To: JAMES E GILLILAND 2007 DOUGLAS DR CARLISLE, PA 17013 COMPLAINT 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 continuar la demada en contra suya sin previo Avisa o notificion. Ademas la corte puede decidie a favor del demandante y requiere que usted compla con todas las provisiones 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 ESCRTTA 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 JAMES E GILLILAND, 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, JAMES E GILLILAND, is an individual residing at 2007 DOUGLAS DR, CARLISLE, PA 17013. 2. The claims raised in the complaint are subject to an agreement to submit these claims to arbitration. <Exhibit C> 3. Defendant, JAMES E GILLILAND, is indebted to MARYLAND NATIONAL BANK, N.A. on an account stated by and between them in the amount of $7,717.81 which balance was due and unpaid as of July 30, 2007, for credit card account number 4264299999713432. <Exhibit A> 4. On or about September 4, 2007, MARYLAND NATIONAL BANK, N.A. sold the debt for good and valuable consideration to plaintiff, CACH, LLC. <Exhibit B> 5. The Defendant, James E Gilliland, last tendered a payment on March 30, 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 $3.0110 per day from the default date ( 14.240% annual percentage rate x $7,717.81 / 365 days) or $3.0110 x 600 days = $1,806.60; 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 $1,543.56 as stated in the Cardholder Agreement attached hereto as <Exhibit C>. 9. The defendant, being indebted to the plaintiff in the sum of $11,246.47 upon the account stated by and between them did promise to pay said sums upon demand. Demand has been made for payment of $11,246.47 and the defendant has failed to remit payment. WHEREFORE, plaintiff demands judgment against the defendant for $11,246.47 together with other interest and costs of suit. Date: June 29, 2009 EXHIBIT A WACHOMEA Preparedtor.• JAMES E GILLILAND 4264 2992 6633 1041 Summarv of Transactions Previous Balance $7,370.06 Payments and Credits $0.00 Cash Advances + $0.00 Purchases and Adjustments + $0.00 Periodic Rate Finance Charges + $86.75 Transaction Fee Finance Charges + $0.00 New Balance Total $7,456.81 May 2007 Statement Credit Une: $7,500.00 Cash or Credit Avai/able: Billing Cycle and Payment Information Days in Billing Cycle 30 Closing Date 05/18/07 Payment Due Date 06/14/07 Current Payment Due $101.00 Past Due Amount + $403.00 Total Minimum Payment Due FIA CARD SERVICES'" Mail Payments to: FIA CARD SERVICES P.O. BOX 15726 WILMINGTON, DE 19886-5726 Mail Billing Inquiries to: FIA CARD SERVICES P.O. BOX 15026 WILMINGTON, DE 19850-5026 Call toll-free 1-800-477-9131 TDD hearing-impaired 1-800-346-3178 Corresponding Annual Balance Subject to _ Category Periodic Rate Percentage Rate Finance Charge Cash Advances A. Balance Transfers, Checks 0.039013% IDLY 14.24% $0.00 B. ATM, Bank 0.039013% IDLY 14.24% $1,096.41 C. Purchases 0.039013% IDLY 14.24% $6,315.49 Annual Percentage Rate for this Billing Period: (Includes Periodic Rate Finance Charqes and Transaction Fee Finance Charges.) 14.24% Periodic Rate May Vary 1?" IM OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE IMPORTANT NEWS - TO MANAGE YOUR ACCOUNT ONLINE PLEASE USE WWW.FIACARDSERVICES.COM. YOU CAN NO LONGER ACCESS YOUR ACCOUNT INFORMATION AT WWW.WACHOVIACREDITCARD.COM. 16 0074568100050400000097000004264299266331041 Check here for a change of mailing address or phone number(s). FIA CARD SERVICES Please provide all corrections on the reverse side. P.O. BOX 15726 ., WILMINGTON, DE 19886-5726 I„1 III 1 1111111111111111 111 I1 I a I I I I I I I I I I I I I I I I I I I I I ACCOUNT NUMBER' 4264 2992 6633 1041 NEWBALANCE TOTAL: $7,456.81 PAYMENT DUE DATE.' 06/14/07 JAMES E GILLILAND 2007 DOUGLAS DR CARLISLE PA 17013-1022-076 EIRW ArymsMAma"En Af & Mail this payment coupon along with a check or money order payable to. FIA CARD SERVICES m m 0 N I:5 240 2 2 2 50i: 08889 266 3 3 &04 Le WACH VIA Preparedfor' JAMES E GILLILAND 4264 2992 6633 1041 June 2007 Statement Credit Line: $7,500.00 Cash or Credit Available Summary of Transactions Billing Cycle and Payment Information Previous Balance $7,456.81 Days in Billing Cycle 32 Payments and Credits $0.00 Closing Date 06/19/07 Cash Advances + $0.00 Purchases and Adjustments + $39.00 Payment Due Date 07/14/07 Periodic Rate Finance Charges + $93.65 Current Payment Due $147.00 Transaction Fee Finance Charges + $0.00 Past Due Amount + $599.00 New Balance Total $7,589.46 Total Minimum Payment Due ACCOUNT NUMBER.- 4264 2992 6633 1041 Posting Transaction Reference Account Purchases and Adjustments Date Date Number Number Category Amount OVERLIMIT FEE (BASED 06/19 06/19 C/00 C 39.00 ON BALANCE 7,550.46) Corresponding Annual Balance Subject to Category Periodic Rate Percent a Rate Finance Charge Cash Advances A. Balance Transfers, Checks 0.039013% DLY 14.24% $0.00 B. ATM, Bank 0.039013% DLY 14.24% $1,109.75 C. Purchases 0.039013% DLY 14.24% $6,392.33 Annual Percentage Rate for this Billing Period: 14.24% (Includes Periodic Rate Finance Charges and Transaction Fee Finance Charges.) Periodic Rate May Vary OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS IMPORTANT NEWS - TO MANAGE YOUR ACCOUNT ONLINE PLEASE USE WWW.FIACARDSERVICES.COM. YOU CAN NO LONGER ACCESS YOUR ACCOUNT INFORMATION AT WWW.WACHOVIACREDITCARD.COM. 16 0075894600074600000097000004264299266331041 Check here for a change of mailing address or phone number(s). FIA CARD SERVICES Please provide all corrections on the reverse side. P.O. BOX 15726 WILMINGTON, DE 19886-5726 loll 1"IIn1111111118111111l1'II111'11III1'?11'11'II JAMES E GILLILAND 2007 DOUGLAS DR CARLISLE PA 17013-1022 076 NEW BALANCE TOTAL: $7,589.46 PAYMENT DUE DATE.- 07/14/07 FIA CARD SERVICES" www.fiacardservices.com Mail Payments to: FIA CARD SERVICES P.O. BOX 15726 WILMINGTON, DE 19886-5726 Mail Billing Inquiries to: FIA CARD SERVICES P.O. BOX 15026 WILMINGTON, DE 19850 5026 Call tollfree 1-800-477 9131 TDD hearing-impaired 1 800346-3178 Eltw Paym"Amprk Ehak-d Mail this payment coupon along with a check or money order payable to FIA CARD SERVICES ? w m o_ N I:5 240 2 2 2 501: 0888 9 2 6 6 3 3 10 4 1113 WACHCVIA Preparedfor.• JAMES E GILLILAND 4264 2992 6633 1041 Summarv of Transactions Previous Balance $7,589.46 Payments and Credits $0.00 Cash Advances + $0.00 Purchases and Adjustments + $39.00 Periodic Rate Finance Charges + $89.35 Transaction Fee Finance Charges + $0.00 New Balance Total $7,717.81 July 2007 Statement Credit Line: $7,500.00 Cash or CreditAvailab/e: Billing Cycle and Payment Information Days in Billing Cycle 30 Closing Date 07/19/07 Payment Due Date 08/15/07 Current Payment Due $143.00 Past Due Amount + $746.00 Total Minimum Payment Due FIA CARD SERVICES"' Mail Payments to: FIA CARD SERVICES P.O. BOX 15726 WILMINGTON, DE 19886-5726 Mail Billing Inquiries to FIA CARD SERVICES P.O. BOX 15026 WILMINGTON, DE 19850-5026 Call tollfree 1-800-477-9131 TOD hearing-impaired 1 800-346-3178 L Posting Transaction Reference Account Purchases and Adjustments Date Date Number Number Category Amount OVERLIMIT FEE (BASED 07/19 07/19 C/00 C 39.00 ON BALANCE 7,589.46) RM O P Annual Balance Subject to Category Periodic Rate Percentage Rate Finance Charge Cash Advances A. Balance Transfers, Checks 0.039013% DLY 14.24% $0.00 B. ATM, Bank 0.039013% DLY 14.24% $1,123.24 C. Purchases 0.039013% DLY 14.24% $6,510.61 Annual Percentage Rate for this Billing Period: (Includes Periodic Rate Finance Charges and Transaction Fee Finance Charaes.) 14.24°% Periodic Rate May Vary OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS 16 0077178100088900000097000004264299266331041 Check here for a change of mailing address or phone number(s). FIA CARD SERVICES Please provide all corrections on the reverse side. P.O. BOX 15726 WILMINGTON, DE 19886-5726 ACCOUNT NUMBER.' 4264 2992 6633 1041 NEWBALANCETOTAL: $7,717.81 PAYMENT DUE DATE.' 08/15/07 JAMES E GILLILAND 2007 DOUGLAS DR CARLISLE PA 17013-1022-076 Entw Porn"A-V ak-.bm& Mail this payment coupon along with a check or money order payable to: FIA CARD SERVICES w = m 0 N ,: 5 240 2 2 2 50I: 08889 266 3 3 L04 ill' EXHIBIT B CERTIFICATE OF PURCHASE I, J F I !' A S AB 0 n( R A c c, 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: JAMES E. GILLILAND Original Creditor: MARYLAND NATIONAL BANK, N.A. Account Number: 4264299999713432 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. Sworn an4 s+bscribed to before me this ay of 2009. otary Public F ANIE MORRIS ARY PUBLIC 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 right 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 give you this notice to tell ou about our choice to F?apit marketing from all t)ie Bank ofyAmerica atBliated companies. You may limit all the Bank of America affiliated companies, such as the banking, loan credit card, insurance and securities companies, A;m marketing their products or services to you based upon your personal information that the receive from other Bank of America companies. Tme information includes your income, your account history, and your credit score. Your choice to limit marketinngg offers from the Bank of America affiliated companies will apply for at least 5 years from when I?ou tell us your choice. BefowiAreyour choice to limit marketin offers expires, YOU receive a renewal notice tha? 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 limit marketing offers, and you may, tell us the choices for other customers who are joint account holders with you. 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 appy 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 Insura m Company LaSalle Financial Servigee, Inc. dba LaSalle Insurance services Brokerage and Investments BACAP Alternative Advisors, Inc. 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Managing information about you thiL prepare and provide reports to others as well as to us. 4. Making sure information is accurate We do not share medical or health information among our 5.. Honors references companies, except to maintain or collect on accounts, Honoring your preferences process transactions, service customer re a or perform 6. Actions you can take insurance Ametions to the extent permitted bg law. 7. Guarding your own information Managing information with companies that work for 8. Bank of America companies the IInnformaat with coommpanies that awdr or us incltud ng This policy covers Customer Information, which means companies located outside the United States. 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We maintain physical, electronic In addpition, we may share any of carte of Customer aAAnppdpprrpoorppoceduraleguarda to protect Customer Information. Information with companies that work or us in order to Inforniatioa formspef blo authorized to access Customer provide su port and other services, such as a ukiness purposes sly. Our empl are 7to ce rovider ths distributes marketing materials. Theme bound by a code of ethics that requires tial es msy help us to market our own products and treatment of Customer Iafor7nation and subject ces or other products and services that we believe may disciplinary action if they fail to follow this e. be ;Finterest to you. Please note that some of our own 2. 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Nevada law r e that we also provide you with the following contact information: Bureau of (consumer Protection; Office of the Nevada Attorney General, 555 East Washington Street, Suite 3900, ?I . r ' Lae Veggaas, NV 89101; phone number: 702.486.3132; e-mail: BCPINFO®ag.statemv.us. Bank of America, PO Box 25118, FL1-300-02-07, Tampa, FL 33633-0900. For Vermont and California residents only. The information Sharin racticea described above are in accordance with fe?er 1 law. Vermont and California law lace 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 collect 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'q accounts or to other financial institutions with which we have Joint marketing a nto. Bank of America will not share Application ?tion Consumer Report Information and information m Outside Sources about Vermont residents ai the Bank of America ompanies except with the autho ation or consent of the ? exT nt resident. California: In accordance with California law, Bank of America will not share information we collect about California residents with co auies outside of Bank of America, except as permit teidby law, Such as with the consent of the customer, to service the custo??paer's accounts, or to fulfill on rewards or benefits. We w[ll limit among our companies to the extent required by apph? ble i? California law. 8Uc?ursall baancareiadde ?ppooleccali n eapariol a traula de la m 2007 Bank of America Corporation. i i CREDIT CARD AGREEMENT YOUR CONTRACT WITH US Promise To Pay, and How We Allocate Your Payments). We reserve gtthe r1?ght to chaanngggg the terms of this sect; led We May Amy N. er described in the Th Agreement. WORDS USED OFTEN IN THIS AGREEMENT "Access check" means a check we provide to you to obtain credit on your account. "Agreement" or "Credit Card Agreex?ent" means this document and any changes we make to this document from time to time. "APR" means the correspondi4g Annual Percentage Rate. The APR corresponds to theaily Periodic Rate ("DPR") which is calculated by dividing the corresponding R by 365. any other personlwiith auuthhorizatiio forlusse e on thisusc urn pursuant to this Agreement. "Default Rate" me the APR(s) which may be applied to Balance Transfers, Cash Advances, and Purchases without r not descriebed initthhe isnectcertain ioled, AAnnual of r engage Rat ate "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 on7oour monthly statement. To determine the New Balance dotal, we start with the total balance at the beginningg of the billing cycle, which is the 'Z'revious Balance." `then we Advances, p13e nsnce Transferscre , its. chanses? and Ad, add Cash and finance charges. "Pay in Full" orr"?"Paid in Full" means payments and credits bill least cycle's NewgBalance?Tot?algIn ge ern a1,yP iaFnollmust'?be made by the Payment Due Date in order to get a Grace means limited time on certain Salar?wa nun corers may or promo}}tiio?on??al ins the section "B lannceeTTrannsfers,CCaashs Addvanceess(sand ??ws. effect for "We", "us" "Our", and "?qCS" means FIA Card services, NA., also frown as Bsnk of America. "You" and "Your" mean each and all of the parsons who are granted, accept o use an account we hold. ''You" and "your" also mean any oUr person who has guaranteed payment of this account, when used in the sections titled Your Contract Arbitration and Liitiga ion,,aandRwh n uuseed iron each of the sections relating to payment of this account (e.g., Your OTHER TERMINOLOGY We will use the definitions described under the section heading Words Used 0 en In This Agreement or as otherwise defined in this rag, If we use a capitalized document thiterm s document hbas the the meaning as used iinmyothis ur monthly statement. We use section headings (e.., Words Used O/kn In This Agreement) to organize this Agreement. The headings are for reference purposes only. HOW TO USE YOUR ACCOUNT You may obtain credit in the form of Balance Transfers, Cash Advances, and purchases by using cards, access checks, your account number, or other credit devices. "Balance Transfer" means a transfer of funds to another to creditor initiated by us at your request. A Balance Transfer t Ad do" not Balance Transfers ionncludetTra onsaacetiioon FeesCand 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. ("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) ("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 ("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 ("Returned Payment'). "Cash Advance" includes Transaction Fees and adjustments associated with any Cash Advance. "Purchase" means the use of your card or account number to: 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. 2008 ANNUAL PERCENTAGE RATES tram This section provides the Standard Rates, Default Rates and PPrroa Promotional Offers applicable to your account. in Fe its Balance Transfers:. The Standard Rate for Balance Transfer balances i a corresponding ANNUAL PERCENTAGE RATE of 9.90%(0.02712352 DPR). Cash Advances: The Standard Rate for Cash Advance balances is a cof ondiag ANNUAL PERCENTAGE RATE of 24 999i(0 MCAAw9F this If an l9 8, t account by your statement Closing D; Advances ben .ng 01 Deposits which get thi account as Balance Trs tional Offer will ap ly to eligible to your account hrough your to in February 2009 and this nd on your statement Closing Date eligible transaction does not post to statement Closing_ Date in August otional Offer will end on your e in A 2008. Check Cash tr ID IiIV MB and Direct Promotional Offer will post to your . DPRl. During the time in which you may??make qualibing under this Promotional e Off, they will b Purchases: The Standard Rate for Purchase balances is a subject to the following Promotional Fees: er, corre on ANNUAL PERCENTAGE RATE of 9.90960.027 392 DPR). Balance Transfers: 3.00% of each such uali?? Default Priai transaction (Fee: Min. $10.00; Max. $99.00) (DANCE n: We may increase the APRs on all new CHARGE). and outstanding- Balance Transfer Cash Advance,. and Purchase balances up to the Defanl't Rate, without gg??vv?tnn?g This Promotional Offer mad end at aannyy time if there is 'a you additional notice, each time you have two "deefault "promotion turn-off event. A promotion turn-off event re-prising events" in twelve roving consecutive billing mesas: (1) that any Total Minimum Payment Due is not cycles. A default re-priein? event means: (1) you fail to received by its Payment Due Date; or (2) that your total make any Total Minimum Payment Due by its Payment Due outstanding balance exceeds your credit Limit on ay Date; or (2) your total outstanding balance exceeds your statement Closing Dste. If a promotion turn-off evennt credit limit many time in a billinngg cycle We may elect to occurs then this Promotional Ober will end as of the first set your APRs for Balance Transfer, Cash Advance and dayy of that billing cycle. This means that this Promotional Purchase balances to different Default Rates. Default Rates Rate will not be i i effect in that billing cycle. are variable rates calculated using the Variahio nacre„ to in which the s?ccs def i _1.] __ _ ault reici g event P Rate for romotional Offer ID H6BHHH7MC: The Promotionnal ANNUAL this Promotional Offer ofs 1.99% 0 0UU6452% DPR). This Promotional Offer applies to Purchases each at least 00.00 (each an "eligible transaction" for this Promotional er). ar. Lure we kPRs by at your new Promotional Offers:. From time to time we may make Promotional Offers on certain new Balance Transfers Cash Advances, and Purchases. When a Promotional Otfe? ends, its Promotional Rates will terminate. A. y Balance Transfer Cash Advance or Purchase balance sub to that Promoi:ional Offer will return to its respective Oct Standard Rate or Default Rate as applicable. This Promotional Offer applies to Balance Transfers Direct his?Promotional Offer ID and Check an "el?igibl transacti on" 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 osing Date in August monai vmer -a Iles to new eligible transactions in June 9, 2008. If an eligible transaction posts to it by A at 1, 2008 then this Promotional Offer to ehgtbe straMeactions posting to your account an --mvionai Vner wits end on August 1, 2008. This Promotional Offer mad 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 no it total received by utstand lba Plance?e eede yDate our; o resdi2 t limt y o statement CIDate. If a_ ? promotion turn-off even occurs then this motio al Offer will end as of the first day of that billing cycle. Z means that this Promotional Rate will not be m eet in that hillins e -I- Promotional Offer ID H6BHSH7MD: The Promotional D? AL PERCENTAGE RATE of 1.99% ( 5482 This Promotional Offer applies to B8huwe Transfers Direct D osit Cash Advances and Check Cash Advances fearing t Promotional Offer M (each an "eligible transaction" for Promotional Offer). This Promotional Offers lies to new eligible transactions beginning on June 18, 2008. If an a bible transaction posts to your account by Your statement Q'losing Date in August 2008 then this l'romotioaal Offer will a ppply to eligible transactions postinQQ to ur account through your statement Cloedng Date in March 2009 and this Promotional Offer will end on Your statement Closing Date in March 2009. If an eligible transaction does not post to your account _y your statement Closing Date in August 2008, then the Promotional Offer will end on your statement Cloa?ng Date Ei6008. Check Cash Advances bearing Offer ID and Direct Deposits which get this Promotional Oiler ID H6BMM7MB: The Prompotionall DIUAL Pthis ERCENTAGE RATTEer of 1.99% (0 s 542296 DPR). 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 m make qu ng An increase or decrease in the index will cause a " transactions under this Promotional ?ffer, they wi1T be Correa and subject to the following Promotional Fees: p ay increase or decrease in your variable rates on the first day of your billing cycle that begins in the same Balance Transfers: 3.00% of each such Fgool_if?*in means hate d ute wil j ah pay °n data. An increase in the index transaction (Fee: Min. (510.00; Max. $99.00) (FIN Cl :TThe ar es and have a der periodic rate finance CHARGE). higher Total Minimum Payment Due. If all Street Journal does sot publish the U.S. Prime y . or i c ges the definition of the U.S. Prime B te, Tprhis ttionotturn of vent. Adpromotionmturif off event we may, at our sole discretion, substitute another index means: (1) that any Total Minimum Payment Dua is not CALCULATION OF PERIODIC RATE FINANCE received by its Payment Due Date; or (2) that yo ur total CHARGES outstanding balance exceeds your credit limi°on any We calculate Periodic Rate Finance lying statement Cloemg Date. If a promotion turn-off event each Balance Subject to Finance Ch r?seeby pp by a p ?le occurs then thins Promotional OtFer will end as of the first DPR and that result by the number of da day of that billing cycle. This means that this Promotional cle. When Periodic Bate Finance the billing Rate will not be in effect in that billing cycle. g le. accrue on a Balance Transfer, Cash Advance or Purchase balance, those Promotional Offer ID H6BHI{H7MF: The Promotional financercllarges become part of that respective Balance Rate for this Promotional Offer is a co nding tiaeh Advance, or Purchase balance. ANNUAL PERCENTAGE RATE of 1.89% ( 54b296 BILLING, CYCLE DPR Your billin cycle ends each month on a Closing Date determined a? yI us. Each billing cycle begins on the day after This Promotional Offer applies to Balance Transfers Direct the Closing 17ate of the previous billing cycle. Each monthly Deposit Cash Advances and Check Cash Advances iearinstatement reflects a single billing cycle. this Promotional Offer ID (each an "eligible transaction" for- this Promotional Offer). WHEN PERIODIC RATE FINANCE CHARGES BEGIN TO ACCRUE This Promotional Offer a lies to new e ' 'ble transactions Each new Balance Transfer and Cash Advance begins to beginning on Jar 13, 2008. If an elihiibleansaction posts accrue Periodic Rate Finan Char on its to your account by your statement ClosingqDa in date. Balance Transfer acend Cash a Advance balances September 2008 then tisia Promotional Offer wi-II aptly to nmai ning from previous billing eli le transactions Dating to ,,? y ?eecycles accrue Periodic Rate statement Closing Do a in pAril 2009 and this promo Promotions t Fi?anea date from Cthe heck Gadeahy ° noesfilling and cycle. The Balance Offer will end on your statement Clo i'ng Date in April Transfers made b . check is the date the check is first 2009. If an eligible transaction does not post to your account deposited or cashed. The transaction date for a Returned by your statement Closing Date in September 2008 then Payment is the date that the corresponding payment posted tfie Promotional Offer will end on your statement G1losfn to Date is Sel)gtember 2008. Check Cash Advances bearing y° amount. Offer ID HOBHSH7MF and Direct Deposits which ¢et tht I Unless subject to a Grac Period each new Purchase begias Promotional Offer will post to B fj your account as glance to accrue eriodic Rate ?inance on its transaction date or the first day of the hiIling cyc a, whichever date is During the time in which you ma make g' later. Unless subject to a Grace Period, Purchase balances transactions under this Promotional Offer, t will be-e Fi a Charges pgbm ? Hof thee b'? Periodic Bete. subject to the following Promotional Feee: ? first l ? illiag cycle. ualik(i n aVhen applicable, Periodic Rate Finance accrue Balance Transfers: 3.00% of each such transaction (Fee: Min. $10.00; Max. $89.00) (ANA ?• an compound daily on new balances, an balances CHARGE). F owe &, from previous billing cycles. Periodic Bate vnargto will continue to accrue even though you This Promotional Offer maX sad at any time if there is s we?inludetan full amount of any related balances because "promotion turn-off event. A promotion turn-off event calculation of eachh Balance Sub ectdto Finnance CCha?ige. in the means: (1) that any Tots Minimum Pa ent Due is not received by its Payment ue Date; or (2) that total Your Payment Due Date will be at least 20 days from your outstandin balance exceeds credit any statement Closing Date. statement Closing Date. If a motion turn-off event occurs then this Promotional Of eierr will end as of the first GRACE PERIOD day of that billing c cle. This means that this Promotional . You do not have a Grace Period for Bolan Trott Rate will not ba in affoot i" +1,.+ 1,411:.... notion turn-off event occurs d ides August 13, 2008 then t on the last day of that billing VARIABLE RATE INFORMATION We will use the following variable rate formula for variab}e Standard Rates, vari le Default Rates and variable Promotional Rates. variable rates an calculated by adding together an index and a For each variable rate, the applicable margin is disclbove in the section titled, Annual Peresnte89Retea This index is determined on the last business day of each month ("determination date') and is the high U S. prime Rate as published in the "Money Ratee" secon of lye Wall Street Journal at any time within theunma y index was determmiinn ds,Theluinde?x ? to calncu attoo?theea - slurs or % Advances. You will have a Grace Period on new miases, in a billing cycle in which you Paayy in Full from day after the Pay in Full date until the end off' that ing cycle. You wiII have a Grace Period for an entire ing ZI on new Purchases and on Purchase balances wining ilom previous billsng cy?? if you Pay in by Payment Due Dat? intlia? b' prokiopus bilillliing cyc you Paid em &*fe and ,>t during fA TCE ?CBARGE F BALANCES SUBJECT TO gage Balance Metho (including new Balance nafers and new Cash Advances : We calculate rate Balances Subject to Finance Charge for Balance oilers, Cash Advances, and for each Promotional Offer nce eo of Balance Transfers or Cash Advances (1) cal sting a balance for each day in the ent billing cycle; (2) catcutating a daily balance for each prior to the current billing cyr?a that had a "Pre-Cvctp . (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 post' date within the current billing *; (3) adding alI theme balances together; and (4) dividing the sum of the dail? balances by the number of days in the current billing cycle. To calculate the daily balance for each day in the current billin cycle, we take the b:Tnnin$ balance, add an amount equa?to the applicable Daily Periodic Rate multiplligd by the previous day's daily balance, add new Balance Transffers, Cash . Advances. and Transaction.. Fees, and subtract a?plicable payments and credits. If any daily balance is ess 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 beginniag?balance, attributable solely to a 1?•e-( he _ ?-L posted in previous billing Average, Dail! Balance Method (including new Purchases): we calculate separate Balances Subject to Finance Charge for and for each Promotional Offer balance ansietzneS Purchases by: (i) calculating a dailyy balance for each Say in the current billingB ccyycle; (2) add all they balances to r, and (3 d-ividi?ag the sum of the dsi?y balances by the number of days in the current billing cycle. To calculate the daily balance for each day in the current egV cycle, we take the beginning balance add an amount I• to the applicable Dail Periodic RaFs multiplied by the previous day's daily balance, add, unless subject to a Grace Period-now Purchases, new Account Fees, and new Transaction. Fees and subtract applicable payments and its. zero. If in the ZRL t bane is cycle yY u P zero we treat it as the day after that Pay Yun da to islude Full, then he in , we exclude Full, the begiamng balance new Purchases, new Account Feet and new Transaction Fees which posted on or before the Pay in Full date. We include the costs for credit card debt cancellation or credit insurance purchased through us is csilcula ' the beginning Purchase balance for the first da%y of the baling cycle after the billing cycle in which such en AN„ hillna MINIMUM FINANCE CHARGE If the total of the Periodic Rate Finance C rges for all balances is less than $1.50, then a minimum i4NANCE CHARGE of 81.60 will be assessed on the account in lieu of any Periodic Rate Finance Charge. 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: the U.S. dollar amount of each such Cash Advance (Fee: Min. $10.00). If you obtain a Check Cash Advance, we will sense a traneaction fee (FINANCE CHARGE) equal to 3.00% of the U.S. dollar amount of each such Cash Advance (Fee: Min. $10.00). yo C1 CDGDeposit, we will assess a transaction amount of each such Cash Advance (Femme: Min $10 00) dollar If you make a Forei Transaction we will assess a transaction fee (FINANCE CHARGE equal to 3.00% of the U.S. dollar amount of each such oreign Transaction. This is in addition to any other applicable transaction fees. If you obtain an Overdraft Protection Cash Advance, we will trans equal 3.00% of the U.S. dollar fee ( Da ung aech suucchRC ash 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 w ch the fees accrue: A Late Fee if the Total Minimum Payment Due shown on your mo statement is not received by us on or before rts Pa3het ment Due Date. On the Late Fee transaction date: • totaloutstandin balance is $100.00 or lose, ate Fee will be $.00; • if the total outstanding balance is eater than 100.00 but $250.00 or less, the Late Fee will be 29.00; • the total outstanding balance is eater than $250.00, the Late Fee will be $39.h9. A Returned. Payment Fee of 8$39.00 if a payment on your account is returned for ineumocfent 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. nthl saless diraftft,of a xcep fothat thepysix most recent ?monntthly statements and one sales draft will be provided for free. An Abandoned Proerty Fee equal to any costs incurred b us forbicoommp'Vng wi state abandoned property laws, unless Prolu Y applicable law. is linked to ount " If you obtain an ATM Cash Advance, we will ass wisn lsant of America ("checking ess a trap coons occur on your checking accounta,ccsuch as transaction fee (FINANCE CHARGE) equal to 9.0096 of or of debits, that if paid would cause thtransaich! the U.S. dollar amount of each such Cash Advance (Fee: account to W overdrawn Min. $10.00). Overdraft protection transfers in a automatic tra to cover checking account fees. Overdraft If you obtain a Balance Transfer we will assess a transfers are processed after close of business N ro, transaction fee (FINANCE CHARGE) equal to 3.00% of throng _ Friday and are treated as overdraft Prot the U.S. dollar amount of each such Balance Transfer (Fee: Cash AAddvanees. Each day's overdraft transactions q Min. $10.9). totaled and rounded. to t7se next $100 (E25 if you c Your checking account in washingtoa or Idaho: 60 i If you obtain a Beak Cash Advance, we will assess a checking account is opened with ? ilitauy Banff mer transaction fee (FINANCE CHARGE) equal to 3.0091 of t, to your available credit limit, regardless of who - I the U.S. dollar amount of each such Cash Advance (Fee: t overdraft transactions. For example, if your ni Min: $10.9). account has a balance of $i.00 and a check or other if item for $126 is presented for payment, which if paid transoaction feee (FINANCE CH RGI?) equal uo 3 oce09?6 f p=oee tection tramf $2OOaccount willb be made too ' your°vthee account and an O will post to this a this account must overdraft transact day) rounded to tl Hinny the credit is i be round the over whole dos ?erdraft Protection Cash Advance of $200 :count. The amount of available credit on be sufficient to cover the total amount of ions (received by Bank of America that e next $100 increment (but excluding any m fee)- otherwise one or more of the Lions ?or that dax will be rejected. Bailable credit on tl account is greater t transaction amount, but the available it for the overdraft transaction amount to next. $100 increment, then the amount of amount of your availat .e accrued finance chaj e.) We may permit or tection transfer that wo tit on this account; but i an Overlimit Fee durb insfer occurs. s oven icaliv be canceed if th ded to the highest :redit. fund in such may ruse to result any cause you to exceed permit it, you may :he billing cycle in either you or us, or at any time upon your request. Your overdraft transactions remain subject to the terms of our 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. E Y MONITOR AND RECORD TELEPHONE 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 tails to your cell hone from us. For an teI hone or cell phone calls we place to you consent and agree that those calls may be automatmc?y dialed Iand/orpuspe?recorded essages. SAARING INFOR AT ON AGENCIES; 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 credit re orting agencise and information about your transactions with us ant other companies, You authorize us to share such information abou you or your account with our affiliates and others.. You may have the right to opt out of so 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 rep MN:. ite to us at: FIA Card Services NA., ALencies, P.O. Box 17054, Wilmington, D ease 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 C no al?urposes. You may not use a Balance Transfer, or ash Advance, or any ether Cash Advan to make a payment on this or any other credit account wi us or our of Iltates. You may not use or permit your account to be used to make any illegal transactUn. 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 I? by an online merchant does not mean that an ?ternet transaction is legal where you conduct it. We may cliarp your account for such transactions. We will not be Uab1eif 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 mag be liable for all transactions made by that person inclu ing ti 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 ma have the same access to information about the account and its users as the account holders. We may send account materials (cards, statements and noti m cess thosi? maateri'alsls top the person will liable parrtie an todeaautlh liable oriz users. Notice to any of you will be considered notice to all of you. You may allow authorized users on your account in the following ways: (1) b notifyingg us that you want someone added to your account' as an authorized user- (2) by lending your card or account number to another; or (I) by any other ways in which you would be legally considdered to have allowed another to use your account or to be le y prevented from denying that you did so. You must t?Ir care f% before you allow anyone to become. an authorised user. Sy doing so, you authorize the person to use your account to the same extent you can including but not limited to making any purchases, calk advances, balance transfers and alRowng others to use your account. Your account does not permit you to limit the nature or amount of authority you give to any authorised user and you wiR attempt to do no. An authorized user's authority will continue until you both notify us that you are terminating 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 pay 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 ayment Due ate 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 P yme Due will not affect your obligation to make the next Tonttal Minimum Payment Due. If you overpay.. or if them to a credit balance on your account, we will not pay interest on such amounts. We will 'ect payments that are not drawn in U.S. dollars and I= drawn on a financial institution located outside of the United States. We reserve the right to act any payment if your account has a credit balance as of, day we receive that payment. Gen credits to your account, such as those generated by me is or by person-to-person money transfers are not treated as payments and will not reduce your fiotal Minimum Payment Due. ACH PAYMENTS We process most payment checks electronically. We use the information on your check to create an electronic Pondo transfer. Each time you send a you authorize a one-time el "c funds transfer. You authorize us to P-rocQu you. - as a check or paper draft, as necessary. Funds may be con from your account as soon as the same day we receive your payment. You will not receive cancelled check because we amp required to destroy it. Ve will retain an electronic copy. For more information or to atop the conversion of your checks into electronic funds yyour moon ssttaatemtent. Moue number listed o the 8ro P O &IN to us at: Bos 15019, fbmiington, D$ 19865019. TOTAL MINIMUM PAYMENT DUE You may pay your total outstanding balance at any time. 'M continued) Each billin.g cycle, you must pay at least the Total Minimum elect to honor it upon presentment or return it uncredited Payment ue shown on your monthly statement by its to the erson that presented it, without in either case Payment Due Date. The Total Minimum Payment Due is waiting or the date shown on the check. We are not liable the sum of all past due amounts plus the Current Payment. to you or any lose or expense incurred by you arising out of thd action we elect to take 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 (0 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 toy ur account but is returned un aid in a later billing We we will recalculate the Total Minimum Payment Due for the billing cycle in which the payment was originally credited. WHEN YOUR PAYMENT WILL BE CREDITED TO YOUR ACCOUNT We credit paymenta as of the date received, if the payment is: (1) received by 5 p.m. Eastern time; (2) received at the addrove shown in the upper left-hand corner of the front of your monthly statement; (3) pail with a check drawn in U.S. dollars on a U.S. financial institution or a U.S. dollar money order, and (4) sent in the return envelope with only the op portion of your statement accompanying it. Payments received after 5 m. Eastern time on any including the Payment Due 7Date, but that otherwise mee the above requirements, will be credited as of * 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 se 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 subsequently request, accept, guarantee ar use the account are individually and together responsible for any total outetandu1n?gg balance. If you and one. or more ppeersoae are responsible to pqy 'any total outstandi?baIance we may refuse to release any of yrou from Iisbilz until a'll of the cards, access checks and other credit devices outstanding under the account 'have been returned to us and you reppay ue the total outstanding balance owed to us at any ?tme under the terms of this Agreement. DEFAULT You will be in default of this Agreement if (1) u fail to make any required Total Minimum Payment .Due by its Payment Due Date; (2) your total outstand balance exceeds your credit limit; or 83) you fail to abide by any other term of this Agreement. oOur failure to exerdse any of our rights when yyoou default does not mean that we are unable to exercise -those rights upon later default. WHEN WE MAY REgMIE I116iMEDIATE REPAYMENT If twin default, an in addition to our other remedies unTer Agibemeny' we can require immediate payment of your total outstanding balance and, unless prohibited by a licable law and except as otherwise provided under the titration and Litigation section of this Agreement, we can r yon to pay the costs we incur in any collection prr:e, sa well as reasonable attorneys' fees if we refer your acscount-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 without losingg any of our rights under this Agreement. This means that no payment, incIu?? those marked with "paid in full" or with an 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 PAYMENT HOLIDAYS AND REDUCED PAYMENT OFFERS We may allow you, from time to time, to omit a monthly payment or make a reduced ?ppayment. We will notify you. when these options are avails le. If u omit a pa .. t 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 payment on time to avoid a late fee. You must resume ng your regular Total Minimum Payment Due each month fouowing a payment holiday or reduced payment offer. YOU ATTEMPT TO EXCEED The total outstan balance on your account plus authorizations at a."nv - must not be more than your credit limit. If you attempt a transaction which results in your total outstanding ? balance (plus authorizations) exceeding your credit liaut, we may: (1) permit the transaction without raising your credit Iimit; (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 raft 5w to permit a Check Cash Advance or Balance Transfer we may do so by advising the person F resentin , the Check Cash Advance or Balance Transfer hat credit has been refused that there are insufficient funds to pay 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 liml which could r a promotion turn-off ?n we may stso charge an Ovmit Fee as provided in AgreemeAt. WE MAY AMEND THIS AGREEMENT We may amend this.. Agreement at any time. We may amend it by addle deleng, or changing provisions of this mint. le may increase or decrease any or all of your which eexce ythe De efaultt Rate 1 When weamamend rates tis Agreement we will comDly with the annheahla nntim rc uli'tlmume m zeaerar ana Lelaware law that are at that time. The amended Agreement (including ar rate or other higher cbarrm ar faml -11 ¦nnly *n "m am uumenr: nocame eznectuve. u as amendment gives you the opportunity to reject the change, and if yyoou reject the chance in the manner provided in such amendment, we may terminate your right to receive credit and may ask you ion. to return alb credit devices as a condition of your We may replace your card with another card at any tune. WE MAY SUSPEND OR CLOSE YOUR ouA?CCOUNT close tereminnaatye ?riNd right toe your aunt. We may do this a any time and for any reason. Your obligations under this Agreemea continue even after we have one this. You must dest? all when was ress cht ? or other credit devices on the 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 othr 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 acco authorized to c internet service companies. Them to your account believe you have to use your acco account, we may account. ant is closed, you must contact anyone barge transactions to your account, such as providers, health clubs or Maurance ae transactions may continue to be charged until you change the billing. Also, if we authorized a transaction or are attempting unt after you have requested to close the allow the transaction to be charged to your REFUSAL TO HONOR YOUR ACCOUNT We are not liable for any refusal to honor your account. This can include a refueal to honor your card or account number or any check written on your account. We are not liable for an 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 anioua and payee exactly as they appear on the access check Oral and written stop pa ant re queats 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 it 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 t1r 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 If you make a use, into a conversion rate to rate or (2) a Bove prior to the proces effect on the pros effect on the trans C IN FOREIGN CURRENCIES Lion in a foreign currency, the verted by Visa International or depending on which card you amount in accordance with the conversion procedgres.in effect at in is processed. Currently, those ores provide that the currency d is either (1) a wholesale market '-mandated rate in effect one day te. The currency conversion rate, in AAf.A rnAv AiffAr f nm tha rate in or benefits and services services are not a p+ t to the terms and i documents provided to you from tfine to time Dy or on behalf of Bank of America. While any benefits or services descrn in the revious sentence are not a part of this Agreement, any be or dispute related to any such benefit or service ahsll subject to the Arbitration an Litigapion section of this Agreement. We may adjust, ado or delete benefits and services at any time and without no ce 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 yeement, or our rigs m to obligations under your accoui or this Agreements to any person or entity. The person or entity to wh we ml any such sale, ant or transfer shall entiteWeto air of our rights andTor obligations under this Agreement, to the extent sold, assigned or transferred. YOU MUST NOTIFY US WHEN YOU CHANGE YOUR ADDRESS We strive to lisp accurate records for your benefit and ours. The post office and others may notify us of a change to your address. When you change. your address, you must notify us promptly of your new adress. WHAT LAW APPLIES This g7ment, is made in Delaware and we extend credit to youm Delaware. This A meat is governed by the laws of the State of Delaware without reward to its conflict of laws principles) and by any applicable federal laws. SETHEE PPRROV SIONS OF THIS AGREEMENT ARE If any provision of this Agreement is found to be invalid, the remauung provisions will"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 unauthon'zed use of your account at 1.80U.789P01. ARBITRATION AND LITIGATION This Arbitration and Litigation provision appplies to you unless you were Xiveu the opportunity to reject the Arbitration and Litigation ppro?visions and you did so reject them in the manner and timef?ame required. If you did re,?ect effectively such a provision, you agreed that any litigtion brought by you against us regarding this account or this Agreement shall be Brought in a court located in the State of laware. Aay claim or dispute ("Claim") by either you or us against the other, or a at the employees, agents or assigns of the other, arising from or relating in any w to this Agreement or any prior Agreement or your accounnt (whether under a statu . in contract, tort, or otherwise and whether for money damages, psnatties or declaratory or equitame renei), -ball, upon election by either you or us, be resolved by binding arbitration. The arbitrator shall resolve any Claims, including the applicabilittyy of this Arbitration and Litigation Section or the validity of the entire Agreement or any nor Agreement except for any Claim chalri Ongg the validity of the Class fiction-Waiver, which shall be decided 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, removod 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 ju ut has been rendered or the other party would suffer substantial prejudice by the delay in demanding arbitration. or or unwuung to act as arburator, we may nistrative and hearing fees which you are required to W pursue a Claim in arbitration. -The arbitrator will e who will be ultimately responsible for paying those If file a claim against us, in no evenf will y be red to reimburse us for any arbitration nistr?artiv?e nn or at te would fees in an amount greater i a staoo twiitthv jura sedict on. Claim had resolved 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 feed. This arbitration agreement is made pursuant to a transaction involving te commerce and shall be ??oovveereed by the Federal Arbitration Act, 9 L .S.C. §1 1-16 (° X2n. Judgment upon any arbitration award may be entered in any court having a' (continued) lurisdiction. 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 privileeggee recognized by law.. If any party requests, the arbitrator shall write an opinion containing the reasons for the award. No Claim submitted to arbitration is heard by, a jury or may be brought as a class action or an a private 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 (Claim Action Waiver). The parties to this Agreement acknowledge that the Clams 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 Clams Action Waiver im limited, voided or found unenforceable, then the arties' agreement to arbitrate (except for this mentence) null and void with respect to such proceeding, subject to the right to appeal the limitation or invalidation of the on Waiver. The Parties acknowled 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 payment of the debt in full by you, any bankruptcy by you or sale of the debt by us. For the purposes of this Arbitration and Litigation Section, "we" and "us" means FIA Card Services, N AL, its parent, subsidiaries affiliates, licensees, predecessors successor, assigns, an3 any purchaser of your account, anA all of their officers directors employees, "agents and assigns or any and all of E6m. Addihonally, "we or "us" shall mean any third party roviding benefits services, or products in connection v:nth he account (including but not limited to credit bureaus, merchants that accept any credit device issued under the account, rewards or enrollment services, credit insurance companies, debt collectors and all of their offic?err? directors, employees and agents) if and only if, such a third party is named by you as a co-de?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 Ri hts and Our Responsibilities After We Receive four 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 questio?dm gg finance charges, and we can ap ly a unp unt against your credit limit. You do not?av to pay any are gstillstoibligated ton pay tthhee paartss p of your?gabillge. that ware notain question. If we find that we made a mistake on your bill, you will not have to V? any_finance charges related to any questioned amount. If we dtd not make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send u a statement of the amount you owe and the date that i is due. If you fail to pay the amount that we think you owe, we may re ort u as delinquent. However, if our explanation does not sat? you and you write to us within twenty-five (25). days telling. us that you still refuse to pay, we must tell anyone we re rt 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 yoto 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 witsi a credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay 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 yyoour 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 B1T.LINU} RIGHTS 02007 Bank of America Corporation. All rights reserved. Keep This Nottttce 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 Bilh If you think your bill is wrong, or if you need more information about a transaction on your bill, write us on a separate sheet yo (o use a cop of the form provided on our biII at Bask of America corporation, F.O. Bo: 15026, Wigton, DE 19860. Write to us as soon a4 possible. Do not Benda the notice on ar with your payment. We moat hear o later t rb on hich the hone but doiletter, give us the follow?n? information: (1) your name and account number, (2 the d0Ilar amount of the suspected error. (3) the posting late of the transaction in question; and ?4j a description of the error and an explanation, if you can, oorr 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 I, JESSICA SNODGRASS 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 JAMES E. GILLILAND owes the balance of $7,717.8 1 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: Authorized Representative Dated: FEB 0 5 2009 PA 5.15.08 F OF TviE ay L y ti C.li G ?J 4`78.60 QD AT" cv.v .o'1 oaq p, "us Jo y Sheriffs Office of Cumberland County R Thomas Kline Sher ~~~~ti,~r of t~~~~u,b~rr~~tr~ 4F~E~E v~F r~6 5rER1FF t-lLE,.~-- ~ ,_ J, Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Cach, LLC vs. James E. Gilliland Case Number 2009-4764 SHERIFF'S RETURN OF SERVICE 08/07/2009 02:56 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August 7, 2009 at 1456 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: James E. Gilliland, by making known unto himself personally, defendant at 19626 Fry Loop Avenue Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 August 10, 2009 . S~O ANSWERS, R THOMAS KLINE, SHERIFF e,~ Deputy Sheriff w " ` ti ~.`. ~; Law Firm of Allan C. Smith, P.C. Attorney L.D. 204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399// (215) 428-0666 Attorney for Plaintiff L_ L. T~.~~ i'~~7HQN~JTAt~'r' cui~ ~~1~ ! 3 P~ 2~ 27 r~Vl~Ek\~N1~~ CQV~1 ~i ~EhNSYLVANIA CACH, LLC. 4340 S. MONACO STREET, 2"D FLOOR DENVER, COLORADO 80237 Plaintiff(s), vs. JAMES E GILLILAND Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV Docket No: 2009-04764 PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Please enter a Default Judgmf:nt in favor of plaintiff, CACH, LLC, and against tlke defendant(s), JAMES E GILLILAND, for failure to answer or otherwise respond to tl~e Complaint in Civil Action. The Complaint was served upon the defendant(,s) on August 7, 2009. A copy of tl~e proof of service is attached hereto as Exhibit "A". A copy of the Notice of Intention to take Default mailed to defendant(s) JAMES E GILLILAND by regular United States mail, postage paid, on July 18, 2012, is attached here~o as E7 Assess damages in the amount of $ 7,046.47 as follows: [ 1] $11,246.47 being sought ~n the Complaint; broken down as follows: [a] $ 7,717.81 principal; [b] and $1,806.60 inter~st being sought in the Complaint; [c] and reasonable attorney's fees of $ 1,543.56, or $ 150.00 per hour, [d] and Court Costs of $178.50; [e] MINUS $4,200.00 previously paid by the DefendantG Date: August 9, 2012 B y. ~ Z.~ ~ .~~, ~ /t,xc or~~ . ~~ronnagel, Esquire ornev LD. No. 313173 ~ ~~. ~~ ~~ k-~ -~~7y R~a~~ac~~ `-~ ~nfice 1~ Law Firm of Allan C. Smith, P.C. Attorney I.D. 204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399// (215) 428-0666 Attorney for Plaintiff CACH, LLC. 4340 S. MONACO STREET, 2"D FLOOR DENVER, COLORADO 80237 Plaintiff(s), vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL Docket No: 2009-04764 JAMES li; GILLILAND s -. CERTIFICATE OF SERVICE OF NOTICE OF INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT I, ~CORRYN L. KRONNAGEL, ESQUIRE, of full age, certify that I mailed a copy of t~e annexed NOTICE OF INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAUI~.T upon defendant JAMES E GILLILAND by regular United States mail, postage prepaid and ~y certified mail, return receipt requested., on July 18, 2012 at his/her last known address of: ', 1962B Fry Loop Avenue Carlisle, PA 17013-4602 Date: August 9, 2012 -_. 1SIVIlIIA~'Cl, J/Jt~UlIC I.D. Na. 313173 Law Firm of Allan C. Smith, P.C. Attorney LD. 204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399// (215) 428-0666 Attorney for Plaintiff CACH, LLC. 4340 S. MONACO STREET, 2"D FLOOR DENVER, COLORADO 80237 Plaintiff(s), vs. JAMES E GILLILAND s IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No: 2009-04764 CERTIFICATION OF NON-MILITAR1Y SERVICE I, Corryn L. Kronnagel, Esquire 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 JAMES E GILLILAND. 3. Our latest information is that the defendant is employed at unknown. ', 4. 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 oft e Soldiers' and Sailors' Relief Act of 1940, as amended, and as stated in the attach d Department of Defense Manpower Data Center reports. 5. This certification is taken subject to the penalties of 18 PaCSA 4904 relating to unswo~n falsification to authorities. '' Date: August 9, 2012 B y: ~nnagel, Esquire No. 313173 Exhibit "A" Sheriffs Ofti~;e of Cumberland County R Thomas Kline Sheriff , L.~tittr 61 CumGrrtr~le Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant "'c_E -'`'"` "°F'FF Edward L Schorpp ', Solicitor Cach, LLC Case Number vs. 2009-4764 James E. Gilliland SHERIFF'S RETURN OF SERVICE 08!07/2009 02:56 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states That on August 7, 2009 at 1456 hours, she served a true copy of the within Complaint and Notice, upon the withi} named defendant, to wit: James E. Gilliland, by making known unto himself personally, defendant at ', 19626 Fry Loop Avenue Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same,/ time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 August 10, 2009 SO ANSWERS, ~' R THOMAS KLINE, SHERIFF ~' - Deputy Cheriff Allan C. Smith, Esq. Attorney LD. 204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399 // (215) 428-0666 Attorney for Plaintiff CACH, LLC COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY ~. No. 20(19- 4764 CIVIL JAMES E. GILLILAND NOTICE OF INTENT TO Defendant FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT To: JAMES E. GILLILAND 1962B FRY LOOP AVE CARLISLE, PA 17013-4602 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITT N APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH T COURT YOUR DEFENSES TO THE CLAIMS SET FORTH AGAINST YOU. UNLE S YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGME T MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LO~E YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DON T HAVE A LAWYER OR CAN NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFI~E SET FORTH BELOW TO FIND OUT' WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Dated: July 18, 2012 Law Firm of Allan C. Smith, P.C. Attorney I.D. 204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399// (21S) 428-0666 Attorney for Plaintiff CACH, LLC. 4340 S. MONACO STREET, 2ND FLOOR DENVER, COLORADO 80237 Plaintiff(s), vs. JAMES E GILLILAND TO: JAMES E GILLILAND 2007 DOUGLAS DR CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL Docket No: 2009-04764 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified a a Judgment has been entered against you in the above proceeding Indic d bel ~I(3~n- gy. ~ ', Clerk C~ 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: s Attorney: Corryn L. Kronnagel, Esquire at (215) 428-0666 or toll free at (888) 275-6399