HomeMy WebLinkAbout10-2354N
r-- - ' . 1
c_J
-J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND,
COUNTY,
PENNSYLVANIA
y?.
CACV OF COLORADO. LLC.
VS.
NO: iD-(R354 aJEFFERY FELTENBERGER
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 4ga.00 Pa ATN
c?' ac?c?4g
ayoiqlr
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
CACV OF COLORADO, LLC.
4340 SOUTH MONACO STREET 2ND
FLOOR
DENVER, CO 80237
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
VS.
No.:
JEFFERY FELTENBERGER
432 W SHADY LANE
ENOLA, PA 17025
COMPLAINT
To: JEFFERY FELTENBERGER
432 W SHADY LANE
ENOLA, PA 17025
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 provisioner 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 ESCRITA 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, CACV OF COLORADO, LLC., by its attorney Harrison Ross Byck, by way of
complaint against Defendant JEFFERY FELTENBERGER, avers the following:
1. Plaintiff, CACV OF COLORADO, LLC., is a Colorado limited liability company
doing business at 4340 SOUTH MONACO STREET 2ND FLOOR, DENVER, CO
80237.
1. Defendant, JEFFERY FELTENBERGER, is an individual residing at 432 W
SHADY LANE, ENOLA, PA 17025.
2. The claims raised in the complaint are subject to an agreement to submit these
claims to arbitration. <Exhibit C>
3. Defendant, JEFFERY FELTENBERGER, is indebted to MARYLAND
NATIONAL BANK,N.A. on an account stated by and between them in the amount
of $11,535.41 which balance was due and unpaid as of August 30, 2004, for credit
card account number 5490994997924303. <Exhibit A>
4. On or about September 16, 2004, MARYLAND NATIONAL BANK,N.A. sold the
debt for good and valuable consideration to plaintiff, CACV OF COLORADO,
LLC. <Exhibit B>
5. The Defendant, Jeffery Feltenberger, last tendered a payment on September 30, 2008.
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 $5.6824 per day from the
default date ( 17.980% annual percentage rate x $11,535.41 / 365 days) or $5.6824 x
449 days = $2,551.39; which is accrued interest through the date of filing. <Exhibit
A> Plus an award of late fees 0.00, court costs $219.00 and reasonable attorneys fees
of $2,307.08 as stated in the Cardholder Agreement attached hereto as <Exhibit C>.
9. The defendant, being indebted to the plaintiff in the sum of $16,612.88 upon the
account stated by and between them did promise to pay said sums upon demand.
Demand has been made for payment of $16,612.88 and the defendant has failed to
remit payment.
WHEREFORE, plaintiff demands judgment against the defendant for $16,612.88
together with other interest and costs of suit.
Date: December 23, 2009
EXHIBIT A
540.0-7 q xjq q x-91 zi43o3
?I
Manafleld Unhremity N
5490 9946 5400 7533
Foundadon, inc.
PAYMENT DUE DATE NEW I?LANCE TOTAL
CARDNDLDER SINCE 2000
09108104 514,204.43
TOT MINIMUM PAY NT DU LINT ENCLO rw
Allis eMek , :1 . 762
Feyesre 10: MBNA AMERICA 09 ??
P.O. BOX 15137
WILMINGTON, DE 19886-5137
JEFFERY FELTENBERGER
TOA VALLEY RD
ETTER5 PA 1T319-891370
S 90000000090000000000000000000000000901429443001762000901GY90994654007533
S •0131d2330012050620000000000000000000142044E001762000008490994i54007533
DAYS IN TOTAL MINIMUM
CCOUNT NUMBER CREDIT LINE CASH OR CREDIT AVAILABLE CYCLE CLOSING DATE PAYMENT DUE PAYMENT DUE DATE
5490 9946 5400 7533 $12.800 32 08/10/04 ;1,762.00 09/08/04
STING TRANS REFERENCE III TRANSACTIONS CHARGES CREDITS (CPO
TE DATE NUMBER P AUGUST 2004 STATEMENT
OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE AND YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS
IMPORTANT
NEWS
ANNARY OF TRANSACTIONS TOTAL MINIMUM PAYMENT DUE
revlous
Wh nl+ Cash
l
FGY + Purchases t Penod1c Rata t Transfalon . Maw Balnce set Dueue Aeount 41.25.0041.25.00
anes nd Credits Advances
[ &Adjudmants Finance ChaMse Finance Charles Total urent Payeent ;37.0
{13,982.39 00 00.00
00. 10.00 1222.10 10.00 {11,201.13 Total Rln Paw"nt Due {1,762.00
NANCE CHARGE SCHEDULE Parl k
C Correaaporbinq B81ance
wtyory Rate Annual Subject to FOR YOUR SATISFACTION
EVERY HOUR
EVERY DAY
A. BALANCETRANBFER. CHECKS .049200%DLY ,
,
Pertantage Rato Tanana Charges - For our automated Direct Connect servia, call
17
98% 00
00
8. ATIA BANK .... - .. .040190% DLY
PURCHASES
0 .
.
I-SCO-7064M
17.90% 90.00 - To speak 10 one of our Customer Safi diction repreae"wwas,
.
........ .040200% DLY
10OTHER BALANCES, ..... .000000% DLY 17.90% 014, 009.62 Cali 1-000-799-67011
0400% 00.00
R TXI6 BIWNO PERIOD For TDD (Tateoommunloatlons Device for the Dean
UAL PERCENTAGE RATE... 17.98% assistance, call
Inquaw PYrhak Rate Ana Trseetilen Fee Flnana CM eS) 1-900 349 3179
HIS DOCUMENT IS A COPY OF YOUR STATEMENT. IT 18 FOR Billing rlglRS are preserved only by written Inquiry.
UR RlOOROS ONLY. THIS COPY IS NOT AN EXACT DUPLICATE Mail bifflrp fngWrtas and all Other Account
InquiRes to;
NO MAY NOT INCWDE AN1SlAOES wNlCil APPEAR IN THE PAGE 1 OF 1 MBNA AMERICA P.O. SOX 16028
MPONTANT NEwa BLOC' ON YOUR C IWINAL PERIODIC STATEMENT
. WILMINGTON. DE 19890-60129
Mansfield University ACCOUNT NUMB 90 9946 5400 7533
Founcefion, Inc.
PAYMENT DUE DATE NEW BALANCE TOTAL
CARDHElLDlR SINCE 2000
1 06/09/04 $13.982.33
TOT MINIMUM PAYM O E AMOUNT ENCLOSED
M.b Cheek $1,525.00
P"ble to: MBNA AMERICA 09
P.O. BOX 15137
WILMINGTON, DE 19886-5137
G
JEFFERY FELTENBERGER
70A VALLEY RD
ETTERS PA 17319-891370
S 00400000000000000000000000000000000001398233001525000005490994654007533
S O41406144001203062000000000000000000413952380015250000054909!4654007533
DAYS IN TOTAL MINIMUM
UNT NUMBER CREDIT LINE CASK OR CREDIT AVAILABLE CYCLE CLOSING DATE PAYMENT DUE PAYMENT DUE DATE
5490 9946 5400 7533 $12,800 30 07/09/04
1 $1,528.00 08/00/04
_
STING TRANS REFERENCE CA TRANSACTIONS CHARGES CREDITS (Cot)
ATE DATE NUMBER ,a JULY 2004 STATIMM
PA AND C1111011111
0610 17100078080 MC EXPRE88PAVIUM-THANKYOU 325.00 CR
0623 17500200467 SAC PAYMENT-THANKYOU 325.00 CR
CAN ADVANCE TRANBACTIONO
0023 0610 171000700(13 MC B OHEOK RETURNED UNPAID 325.00
WWTMEYTi
FW C
063 0020 17108070033 MC C RETU
HECK FEE
39.00
TOTAL FOR BILLINO CYCLE FROM 11MO/2004 THROWN 7/00/084 0364.00 0650.00 CR
OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE AND YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS
IMPORTA
r
I
UMMARY OF TRANSACTION
I TOTAL MNIMUM PAYMENT DUE
revious P moots + Cash
Bal
i
d + Purchases +
periodic Rate 1+
Amoun1
Balance ast sus
t x1,268.00
i
i
T
h
ance an
Cred
te Advances wmen
OAdjustroants Finance Charges Fin
a tp,
i
o
l
urrsnt Parent x260.00
014,061.{. x650.00 0325.00 x39.00 $206.09 x0.00 513,952.33 otal NSA Patraent Due 01,525.00
NANCE CHARGE SCKEDUIF Period lC
C
t C01Ta Ing Balance
e
araory Rata Annual Subject to FOR YOUR SATISFACTION
EVERY HOUR
EVERY DAY
,
,
Percentage Rats Rnance Charges For our automated Direct Connect service
cal(
A BALANCE TRANSFER C>1L:= .040200% DLY ,
17.80% 00.00 1000 7„-eEE3
8. ATM, BANK ....... .0401001E IDLY
C
PURCFtAM 17.08% 40.00 To speak to one of our Customer Satisfaction representatives,
.
........ .040200li DLY
D. OCHER BALANCES...... .000000% IDLY 17.00% 013,999.63 call I-800,780.8701
00600% 00.00
POR THIS aILLNO PERIOD - For TDD (7a laoommunlcaflons Device for the Dent)
NUAL PERCENTAGE RATE ... a/
1 7.98% asststenea, qll
(MeWe Perioehl Ra1? AM TFWAKtlon FN F mnft Ch@rpW 1-800-318.3178
TKIS DOCUMENT 15A COPY OF YOUR STATEMENT. IT IS FOR - Billing fights are preserved only by written Inquiry.
YOUR RECORDS ONLY. T141S COPY IS NOT AN E11ACT DUPLICATE Mall billing inquiries and all other account inquiries to:
AND MAY NOT INCLUDE MESSAGES WHICH APPEAR IN THE PAGE 1 OF 1 MISNA AMERICA P.O. BOX 15028
IMPORTANT NEW, BLOCK ON YOUR ORIGINAL PERKIDIC STATEMENT
. WILMINGTON. DE 18850.6026
0 N NUMBER
p
Mansfield Univeralty 5490 9946 5400 7533
Foundation, Inc.
PAYMENT DUE DATE NEW 9A CE TOTAL
CARDMLDER SINCE 2000
07/0@/04 $14,061.44
TOTAL MINIMUM PAYMENT DUE AMOUNT CL SE
Mate check $1,590
p gable m: MBNA AMERICA 09
P.O. BOX 15137
WILMINGTON, DE 19886-5137
E
JEFFERY FELTENBERGER
70A VALLEY RD
ETTERS PA 17319-891370
S 0000000000000000000000000000900000000140i144001590000005490994654007533
3 0013816490012030620000600606006000000140614400159$0000054909946W007533
DAYS IN TOTAL MINIMUM
CCOUNT NUMBER CREDIT LINE CASH OR CREDIT AVAILAW CYCLE CLOSING DATE PAYMENT DUE PAYMENT DUE DATE
5490 9946 5400 7533 $12.800 30 06/09/04 $1,590.00 07/08/04
ee
NG TRA
NCE IrAN
S
NS RE M
CHARGES CREDITS C
TRANSACTIONS
A
D O
MTE
E alINOE Y004 $TATE0IENT
PAY111111111111711 AND
0820 14190070092 MC EXPFIM PAYMENT-THANKYOU 325.00 CR
0625 146007ti9410 MO PAYMENT•THANKYOU 325.00 CR
ADVANIT
N
NPA
P
0020 064!0 14190070002 MC B ID
RETUR ED
325.06
CHEOK
UU
0628 0605 14000700440 MC B CHECK RETURNED UNPAID 326.00
USTMENTi
AND ADJ
RN0
064$5 0625 141900790352 MC C RETU
39.00
51ECKFEE
TOTAL FOR 811L4N0 CYCLE FROM 6/11/2004 THROUOM 9/00/2004 0689.00 0660.00 CR
OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE AND YOUR SAIANCE EXCEEDS APPROVED CREDIT LIMITS
IMPORTANT
NEWS
MMARY OFT SACTMO TOTAL MINIMUM PAYMENT OUR
Previous • Payments + COS"
Pwchases
+ PeflOdk Rah + Trensactlon a New Balance
ast Due Aaaunt $1,833.00
9alanee and Credits Advances j l?adjustmants Finance Cheogaa frinanee Chmrgee Total urrent Pasant {254.00
F
s1a,a16.49 $650.00 $650.00 $39.00 $205.95 $0.00 $14,061.44 T otal "in Payment Due $1,590.00
RANCE CHARGE SCHEDULE Parlodlo Corresepolging Balance
Category Rate Annual Subject to FOR YOUR OATISFACTIOM, EVERY HOUR, EVERY DAY
Percentage Rate Finance Charges - For our automated Direct Connect service
call
A BALANCETFIANSFER, CHECKS .0902190%IDLY ,
17.90% $0.80 1-EOo-7964M
B. ATM. HANK........ .0400D0%DLY 17.00 00.00 To speak to one of our Customer Satisfaction representatives
C PURCHASER ........ 104029076 IDLY
D. OTHMIIALANCES...... .000000%DLY ,
17.90% 913, 936.51 cell 1 000 780 6701
00.00% $0.60
For TOD (Telecommunications Device for the Deaf)
POR'UALPER ERs CEMTAtNNTA: RATE . . .
UA 17.98% assistance. Cott
(Inciuiw Periodic NOW AM Transaction In Flrenee cfaryeal
1-SOD-3163175
THIS DOCUMENT ISACOPY OF YOUR STATEMENT. IT IS FOR ' Billing rights are preserved only by written Inquiry.
YOUR RECORDS ONLY. THIS COPY la NOT AN EXACT DUPLICATE Mail billing inquiries and all other account inquiries to:
0 MAY NOT INCLUDE MEaL1OES WHICH APPEAR IN THE PAGE 1 OF 1 M911A AMERICA P.O. SOX 1Q026
IMPORTANT MM N K ON YOUR ORIGINAL PERIODIC STATEMENT. WILMINGTON DE 18860.3046
ACCOUNT NUM R
Mansfield University 5490 9946 5400 7533
Foundation, Inc.
PAYMENT DUE DATE NEW BALANCE TOTAL
CARDHIOLDER SINCE 2000
06/08/04 313,816.48
TOTAL MINIMUM PA ! T DUE UNIT D
M.1.C)mCk
0
$11,331.00
Fgeble m. MBNA AMERICA 09
P.O. BOX 15137
WILMINGTON, DE 19886-5137
E
JEFFERY FELTENBERGER
70A VALLEY RD
ETTERS PA 1T319-891370
s otooeoeooeooeeoeooeoooeeooeoeeteteoeol381649ee1a33eeoets49e9946a4oe7aaa
3 0013935830012030620000e00e0e00e00000013816490e1331e00005490994654007533
DAYS IN TOTAL MINIMUM
URT RUMMER CREDIT LINE CASH OR CREW AVAILAALE CYCLE CLOSING aATE PAYMIINT DUE PAYMENT DUE DATE
5490 9946 5400 7533 $12,800 30 05/10/04 31,331.00 06/08/04
STING TRANS REFERENCE a
G SADTIONS CHARGES CREDITS (CR)
TF DATE NUMBER S MAY 2006 STATEMENT
PAYM
0490 121te67S031 MC EXPREGS PAYMENT•THANKYOU 50.08 CR
TOTALRO81LL111RCYCLEFROM 411112004THROURN 5H0/4004 0.00 0325.00 CR
OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE AND YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS
IMPOR
TS
SUMMARY OF TRANSACTIONS 70TH MINIMUM PAYMENT DUE
Previous Payments
+ Cash
+ Purchases
+ Periodic Rata
+ Transaction - Now Balance
ast Do* Amount
>R1,11.00
1
its
Satance end Crad Advances dJW)ustmer" Finance Charges Finance Changes Total rent Payment $220.00
$13,995,93 $325.00 $0.00 $0.00 x205.66 $0.00 513,016.49 stel Min Peyaent Duo $1,331.00
NANCE CHARGE SCHEDULE Parlodlc COnesaperlding Boo snce
l aiepery Rate Annual Subject to FOR YOUR sATHiFACT101" EVERY HOUR
EVERY DAY
,
Parton" Rate Finance Charges - Por our sub* mated Dlrad Conned *Wea
call
A. SALANOETRANSFER. CNECKB .040200%DLY ,
17.06% $8.00 1-800,
8. ATM, BANK ....... .0490 % DLY 17.56% 00.00 - To spook to one of our Customer Satisfaction rprosentatlves
C. PURCHASES ........ .040200% DLY
M OTHER BALANCER...... .000000% DLY ,
17.00% 013, 916.37 call 1-900-780-67011
00.00% 00.00
FOR THIS BILLING PERIOD For TOO (TN60ommunicadons DrAm for the Deaf)
ANNUAL PERCENTAGE RATE... ".9S?r assistance, call
(Ifowes Perleele Rob And Tmnnetion Fee Flnena Chi 1-80044x3170
THIS DOCUMtINT IS A COPY OF YOUR STATEMENT. IT IS FOR BIII Ing rights am preserved only by written Inquiry.
YOUR RItCOROS ONLY. THIS COPY IS NOT AN DACT DUPLICATE Mail tilling inquiries and all other account inquiries to:
AND MAY NOT INCLUDE MESSAGES WHICH APWAR IN THE PAGE 10F 1 MIBNA AMERICA P.O. BOX 11028
IMPORTANT NEWS K= ON YOUR ORIGINAL PERIODIC STATEMENT
. WILMINGTON DE 18S5D4=
NT NU N
Mansfleid University 5480 8846 5400 7533
[
Foundadon, inc.
I- I
PAYMENT DUE GATE NEW BALANCE TOTAL
CARDHOLDER SINCE 3000
1 05/08/04 $13,835.83
TOT MINIMUM PAYMENT DUE AMOUNT FN 0
M.I. check $1.436.00
IryWle tw MBNA AMERICA 09
P.O. BOX 15137
WILMINGTON, DE 19886-5137 JEFFERY FELTENBERGER E
70A VALLEY RD
ETTERS PA 17319-891370
S aces 90eSoo00090060Bocce Sees* 0900900091395MOo143see0ee5490994654e07553
S 0914039510912039629000009090900o000e01393503901436eee9054999!46&4007533
DAYS IN TOTAL MINIMUM
UNT NUMBER CREDIT UNE CASH OR CREDIT AVAILABLE CYCLE CLOSING DATE PAYMENT DUE PAYMENT DUE DATE
8490 8846 5400 7533 =12,800 32 04/10/04 $1,436.00 05/09/04
STING NFERENCE RD TRANSACTIONS CHARGES CREDITS (CR)
TE DATE NUMBER Pc APRIL 2004 STATEMENT
PAYMENTS
0331 00190979030 YC EVNEW PAYMENT-M"KYOU 325.00 CR
TOTAL FOR BILLING CYCLE FROM $11012004 TNROUON 4/10/2044 0.00 0325.00 CR
OUR RECORDS SHOW YOUR ACCOUNT IS PAST DUE AND YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS
IMPORT
?
?
UMMARY OF TRANSACT)ON$ TO7AL MONtNiM PAYMENT DUE
Previous Payments + Cash + Purchases + PalodiCRate t Transao0on New Balance sat o Amount ¢1,200.00
Balance and Credits Advances 6JMlustmanta FleanceChereas Pirlan0e Clleryae Total urrsnt Payment }236.00
¢34,059.59 }325.00 00.00 00.00 }273.29 }0.00 013,935.03 otal "in Payment Due ¢3,436.00
FINANCE CHARGE SCHEDULE Period'- Correseponding Balance
CatpGry Rate Annual --,ad to FOR YOUR SATNIFACTION. EVERY HOUR, EVERY DAY
Percentage Rata R nand Chergas For our automated Dire d Conned servlce, call
A. BALANCETMNSFER, CHEM .04som DLY 17.90% 00.40 14100-790
B. ATM, BANK ....... .049200% DLY 17.90% 00.09 - To speak to oM of our Customer Sabdaetlon representatives,
0. PURCHASES ........ .049200% DLY 17.09% 014j635.32 al I 1-800.7096701
M OTHER BALANCER...... .000000% DLY 00.00% 00.00
For TOO {Telecommuni
ti
D
i
f
h
O
FOR THIS BILLING PaR100 ' 7.98,E
ANNUAL PERCENTAGE RATE... ca
ce
ons
ev
eaq
or t
e
asslolanee, cell
ixluso Perlodk New And Tra mecdoe 149 Fine= CINMW 1.800.3463178
THIS DOCUMENT IS A COPY OF YOUR STATEMENT, IT 19 FOR Billing rights am preserved only by wMt w inquiry.
YOUR RECaiDi ONLY. THIS COPY IS NOT AN EXACT DUPLICATE Mall billing Inquiries and all other account inquiries t0:
AND MAY NOT INCLUDE MESSAGES WHICH APPEAR IN THE PAGE 1 OF 1 MBNA AMERICA P.O. BOX IS=
IMPORTANT NEW! BLOCK ON YOUR ORIGINAL PERIODIC STATEMENT. WILMINGTON DE 1005D411020
Mansfield University NT NUMB 90 9946 5400 7533
Foundation, Inc.
PAYMENT DUE DATE NEW BALANCE TOTAL
CARDHOLDER SINCE 2000
04/09/04 14.039.59
TOTAL MINIMUM PAYM NT DU NT ENCLOSED
?
as efinelc $1.52r
.00
J
=6
1019 10: MBNA AMERICA 09
P.O. BOX 15137
WILMINGTON, DE 19886-5137 E
JEFFERY FELTENBERGER
70A VALLEY RD
ETTERS PA 17319-891370
S 0000009009000less 09oleo 990909990Go09014039590015t5999995499994654097533
S 90141150190120256209009009990008999001493959091525890005490994664097533
DAYS IN TOTAL MINIMUM
UNT NUMBER CREDIT LIME GSM OR CREW AVAILABLE CYCLE CLOSING DATE PAYMENT DUX PAYMENT DUE DATE
5490 9946 5400 7533 $12,600 29 03/09/04 11 $1,525.00 04/09/04
STING MN8 REFERENCE lk-Aa D TRANSACTIONS CHARGES CREDITS (CR)
TE DATE NUMBER MARCH 2004 STATEMENT
PAYMENTSANDCMTI
0220 05199979029 MC EXPRESS PAYMENT -THANK YOU 325.90 CR
0226 05700200425 MC PAYMENT -THANK YOU 325.00 CR
0308 00"=7994 610 IXPREINIPAYMENr-THANKYOU 325.09 CR
CAIN AUVANCE
0226 0290 05140079020 MC 8 CHECK RETURNED UNPAID $0.00
0302 0220 057001299428 MC B CHECK RETURNED UNPAID 325.00
PURCHASES AND ADJUSTMENTS
0217 0217 04VJ10304 MC C FEE FOR STATEMENT COPY 5.09
0220 0228 05199979020 MC C RETURN CHECK FEE 39.09
TOTAL FOR OILLOO CYCLE FROM 4/10/2004 THROUGH 9100/2004 0694.00 $975.90 CR
OUR RECORDS SNOW YOUR ACCOUNT IS PAST DUE AND YOUR BALANCE EXCEEDS APPROVED CREDIT LIMITS
IMPORTANT
NEWS
MMARY OF TRANSACTIONS TOTAL MINIMUM PAYMENT DUa
t Cash + Purchases. + PalledIc RaN + Transadlen a Hw„ Oda
Due Amount $1.2 00
r aea a
i
nd Crsd
ts
Advances IkAdJUStMellts Flnanea Ctnr9es Flinn tharyae Total ont Pwo
ont .
El
4450.00 `44.00 $202.58 42.00 :!1,039.59 l Min PWoont We $1,525.00
MANGE CHARGE SCHEDULE erl c COrtasapondlnq Balance
C
t
a
eyDry Rata Annual Subject to FOR YOUR SATISFACTION, EVERY HOUR, EVERY DAY
Po
Rata Finance
rgas . For our automated Direct Conrad Service
call
1
,
A BALANCETRANSFER CHECKS .049280!6 DLY
'a
1-800-70944
B. ATM, BANK ....... .049200% DLY 17.95% $0.68 • To speak to oM o1 our Cush mar SatlsfvCbcn ropres~K as,
C
PURCHASES
.
........ .049200% DLY 17.98% $14.161.06 all 1800 788701
M OTHER BALANCES...... A00000% DLY 00.00% $0.00
F
TDD
T
HIS BILLING PEWD
'OR or
(
elacommuMcatlons Device for the Deaf)
17.98%
UAL PERCENTAGE RATE...
assistance, call
sa Psrfelle Rob AM Trormseasn Fes Flrmnra Chs ) 1-ti00348 3178
OCUMENT IS A COPY O F YOUR STATEMENT. IT is FOR Billing rights an preaewad only by written Inquiry,
t
s
RECORDS ONLY. TINS Copy 18 NOT AN gK*= DUpUCATE Mall billing frpuiries and all other account inquiries to:
u
ll
AY INCLUDE M554M98 WHICH APPEAR IN THE PAGE 1 OF / MBNA AMERICA P.O. BOX 13028
TANT NEWa BLACK ON YOUR ORIGINAL PERIODIC STATEMENT
l
-
. WILMINGTON DE 19Bt10-b02$
EXHIBIT B
0
1, 1 W V 16 - hereby depose and state that.
1. 1 am an Authorized Agent of CACV OF COLORADO, 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.
FFERY FELTENBERGER
Customer Name: MARYLAND NATIONAL BANK,N..
Original Creditor: 5490994997924303
Account Number.
3. On or about a tem r 16, 20Q4 this account was sold by the original creditor.
CACV OF COLORADO, LLC• is the current owner of the account and
purchased the account for good and valuable consideration.
MAR ti 2 2010
Date: '
By: -??2
Sworn and subscribed to before
`
f' Qw ?:tip
me this _Y f
Notary Public
.,; pTAI?? FLL
B 3
{
G, •
X?G PQO
0P
r "°: Y:iaiun Expires 03/0212011
EXHIBIT C
071/20/2006
15:26 FIA CARD SERVICES 912672952844 N0.873 D002
credit"hard`: raeemenf
ir:e e"o YA71•e'fv
4 j.1
. G? •,i ..,..? ,??,, ??,88 - .?.•.7?'nya.c.?iC+?t•I• '?F.?y. V'-,: •..e•'
?; ':'... s?S.;=r.?r>,', `atilt . ?,..•r:. -' ",.;
' -'?:•`j?tit?ltf?l?!`'i?I?C:Q'1?F?111['?:.::::r::;;s q,i :?,:.
aye lim"M .:.:Z..,
17-
t "'t
1.hat''Lalv. Ap , w ?` {{ M9
?.. - i11:riJ;:J'r.?:"???Yj, `G•?.i??. ,IrM?wL?i?.t
Ott's
-L em
? ? •?4rbitr?tioa??d.tlkl "...._ ':..... .;..`.?.;: ?; .
r.?.., ,.
r .. ? ? wC yyr`?."Lrt'rfi•~ hYr J'.
NEXT90
0
07)120/2006 15:26 FIA CARD SERVICES 912672952844 N0.873 P003
Your Contract With Us
Ypur Credit Card Agreement with us consists of these
A44itional Terms and Conditions and the document called
the Required Federal Disclosures or the initial Disclosure
You•agree to the terms and conditions of this Agreement
Fotthe purpose of the Priwey Native, we will use the definition
contained in the third paragraph of the Privacy Notice. For
the'remainder of the Agreement. we will use the definitions
described under the section heading words Used Often in
Tkis Agreement.
_y Notice
Pr' a
Your pr*mcy is important to as: At MBNA, we are
committed to providing you with the finest financial
products and services backed by consistently top-qualit
service. And while information about you is fundamenta
to our ability to do this, we fully recognize the important,
of keeping personal and account information secure.
To offer you the widest range of products and services
MBNA may share information about you both within
MBNA and outside of MBNA with other companies.
This allows us to offer you products and services that
may interest you and best meet your needs, whether
they are available directly from MBNA or through our
relationships with other companies. We want you to
understand our information safeguards, what information
we collect, what information we sham:. and the benefits
you receive when we share iribmtation about you.
This notice describes the privacy practices of MBNA
Corporation and all MBNA affiliates, including MBNA
America Bank, NA, MBNA America (Delaware), N.A.,
Palladian Travel Services, Inc., MBNA Hallmark
Information Services, inc., MBNA Marketing Systems,
Inc., and MBNA Insurance Agency, Inc. (collectively,
'MBNA°), for financial products and services governed
by the laws of the United States of America. This
notice explains MBNNs information collection and
sharing practices and lets you choose whether or not
MBNA may share certain information about you, either
within MBNA or outside of MBNA with other companies.
Onir Secaft Pmeeditrest MBNA understands: the
importance of protecting and securing information
and using it appropriately. Access to information
about you is restricted to the people of MBNA who
require it to provide products or services to you. We
maintain physical, electronic, and procedural safeguards
that comply with federal standards for the security
of information.
When MBNA shares information about you with
companies outside of MBNA, vm require them to
impose safeguards, use it only for a permitted purpose,
and to return it to us or destroy it once that purpose is
served. We limit the amount of information shared to
what is appropriate to offer a product or service effl-
ciently. MBNA requires any company receiving infor-
mation from MBNA to sign a Confidentiality Agreement
containing these requirements and obligating that
company to protect the information as we would,
i
i
07/20/2006 15:26 FIA CARD SERVICES 4 912672952844 N0.873 9004
Information Wt Collect.; MBNA collects and uses
nonpublic personal information about you to conduct
our business and to consistently deliver the top-quality
Customer service you expect from us. sources of this
information include the following: applications
. information we receive from you on and other forms or through your correspondence or
communication with us including through the mail,
by telephone, or over the Internet: tries such as
• information we receive from third pa
consumer reporting agencies, to verify statements
you've made to us, or regarding your
credit, or other relationships: and
• information about your transactions with MBNA and
with other companies outside of M NA. share
Information We Share Within MB A-. we may
financial
all of the information we collect about you with
service companies within MBNA to offer additional
products or services that may interest you and best
meet your needs. We believe this is convenient do r YOU so. and may save you both time and money.
share identification information (such as name and
address). transaction and experience information (such
as purchases and payments). credit eligibility information
(such as credit reports and applications). and other
information. The decision to purchase any such prod-
ucts or services is yours alone. You may tell us not to
share credit eligibility information about you within
MBNA but you please onal products and services orus undernd this does not prohibit from offering g yo yo
from sharing tmrrsactionmand b?ronncwithin e. MBNA
identification, and other to
Information We Share With Others: From time
time, we may allow companies outside of MBNA to offer
you their products and services that may interest you,
These products and services may be offered by financial
service providers iuuch as banks, loan brokem account
aggregators, insurance apnts, insurance companies,
mortgage bankers. and securities broker-dealers). by
nonfinancial companies (such as retailers, direct mar-
keters. communications companies. Internet service
providers, manufacturers, service companies, travel
agents, cruise lines, car rental agencies, hotels. airlines,
publishers, and organizations endorsing MBNA financial
products or services), and othem Isuch as nonprofit
organizations). Subject to applicable law, we may share
companies out-
all the information we collect ) i not to.
side of MBNA, unless you
Additionally, we may share ail the information
other
collect with companies that perform mar?ting or
services on our behalf or to other financial institutions
with which we have joint marketing agreements. We
are also permitted by law to share information about
you with other companies in certain circumstances.
For instance. we may share all of the information we
collect with companies assisting us in servicing your
loan or account, with companies that endorse our
products and services through affinity agreements.
with government entities in response to subpoenas or
OV20i2006 15:26 FIA CARD SERVICES 3 912672952844 ND.873 9005
regulatory requirements. ano with consumer reporting
agencies. it you tell us not to share information with
companies outside of MBNA that wish to offer you
their products and services, as described above, please
understand that we will continue to share information
in these additional circumstances.
important Iuformndon About Your Choice: We're
dedicated to serving your needs - and to respecting your
choices related to privacy. You may tell us not to share
credit eligibility information within MBNA. and you may
tell us not to share information with companies outside
of MBNA that wish to offer you their products and serve
ices as described above. If you wish to opt out of such
ir?fomlation sharing, please call toll-free 1-866-751-I255.
We will ask you to verify your identity and the specific
' accounts to which the opt out applies. so please have
all your account, membership, or reference numbers
and your Social Security number or Taxpayer
identification number for deposit accounts available
when you call.
? MBNA applies opt outs at the account level. not by
individual Customer. When any person listed with others
s on an account opts out (for example, a co-applicant, joint
account holder, or authorized user), we will list the entire
account as having opted out. MBNA will continue to
adhere to its disclosed privacy practices for an account
even if it becomes inactive or is closed.
An opt out from information sharing on an account
as described above, either within MBNA and/or with
companies outside of MBNA, remains effective unless
I revoked in writing. Federal regulations require us to
provide this notice on an annual basis, whether or not
an account has previously opted out from either type
of information sharing, Please remember when you
receive our subsequent notices that an account previously
opted out from either or both types of information sharing
(and not revoked in writing) does not need to be opted
out again.
This notice updates and replaces any previous
notices from MBNA about the privacy, security, and
protection of information. For additional information
regarding MBNA s privacy practices concerning the
Internet, and to view the most recent version of this
privacy notice, please go to www.mbna.com and click
on -Privacy Notice" You may have other privacy pro-
tections under state laws. We may amend this privacy
notice at any time, and we will inform you of changes
as required by law.
Words Used Often in TWO ,AO!>e+CM1Cnt
Agreemenr or "Credit Card Agreemenr means these
c Additional Terms and Conditions and the Required Federal
Disclosures for the Initial Disclosure) and any changes we
make to those documents from time to time.
-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 aocount, when used in the sections entitled We May Moalror
and Nord TAVAow Ca& and Ariitrstim and tllyatim and when
used in each of the sections relating to payment of this account
07i20i2006 15:26 FIR CARD SERVICES 4 912672952844 N0.873 D006
(Your Prx iSe to Pau and Hou• We Alfaare Your PayfneHl?. for examo
"We," -us." "our', and "MBNA Amenca" mean MBNA
America Bank, N.A
-Card, means all the credit cards we issue to you and tc
any other pennon with authorization to use this account
pursuant 10 this Agreement.
-Access check" means an access check we provide to Yof
make a Check Cash Advance on your account.
if we use a capitalized term in this document but do no,,
define the term in this document, the tern has the meanir
given in the Required Federal Disclosures or the Initial
Disdosure or as used in your monthly statement.
we use section headings isuch as words Used 0/un in "
Agraemcnq to organize this Agreement. The actual terms
this Agreement are in the sentences that follow and not
the headings.
Sign Yow Card
You should sign your card before you use it.
we Menus and Rrflfwd T CA
You consent to and authorize MBNA America. any of its affi
aces. or its marketing associates to monitor and/or record a
of your telephone conversations with our representatives c
the representatives of any of those companies.
CrW it YN11 Mules
You authorize MBNA America to collect information abou-
you, including credit reports frorn consumer reporting agsne
if you believe we have furnished inaccurate or incomplei
information about you or your account to a credit reportin,
agency, write us at: MBNA. Credit Repodina Agencies, P.0
Box 17054, Wilmington, DE 19884-7054. Please include yo
name, address. home phone number. and account number
and eapiain what you believe is inaccurate or incomplete,
How to Use Your Amunt
You may obtain credit in the form of Purchases and Cas
Advances by using your cards. aaoess cheeks, account nun..
ber, or other credit devices. Please refer to your Required
Federal Disclosures or initial Disclosure to determine what
transactions constitute Purchases and Cash Advances and
how you may obtain them.
Transacdon Date for Ca?tain Cask Advanc
The transaction date for Check Cash Advances and Bala
Transfers done by check is the date you or the person to
whom the check is made payable first deposits or cashes t
check The transaction date for a returned payment (whicl
will then be classified as a Bank Cash Advance) is the date
that the corresponding payment posted to your account.
Pu oses ft! Using Your Accmt
You may use your =unt far personal, family, or house)
purposes. You may not use your account for business or
commercial purposes. You may not use a Check Cash
Advance, or any other Cash Advance, to make a payment k
this or any other credit account with us. You may not use c'
permit your account to be used to maize any illegal transact
Persons Using Your Account
if you permit any person to use your card. access ehe,
account number, or other credit devlce with the authorize
to obtain credit on your account, you may be liable for a
a.
071/20/2006 15:26 FIA CARD SERVICES i 912672952844
I
t
F
f
L
NO.873 9007
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.
How You May Stop Payment on an
Access Check
You may request a stop payment on an access Cheek by
providing us with the access check number. dollar amount. and
payee exactly as they appear on the access check. Oral and
written stop payment requests on an access check are effective
for six months from the day that we place the stop payment.
You Ma Not Poddate an Access Check
You may not issue a postdated access check on your
account, it you do postdate an access check we may elect to
honor it upon presentment or return it unpaid to the person
who presented it to us for payment. without, in either rase,
wafting 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.
Your Promise to Pay
You promise to pay us the amounts of all credit you
obtain, which includes all Purchases and Cash Advances,
You also promise to pay us all the amounts of finance
charges. Fees, and any other transactions we charge against
your account.
Payments on Your Account
You must pay each month at least the Total Minimum
Payment Due shown on your monthly statement by your
Payment Due Date, 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 US. dollars and those
drawn on financial institutions located outside the United
States. Payment of your Total Minimum Payment Due may
not avoid the assessment of overlimit Fees.
When Your Payment Will Be Credited
to Your Account
We credit payments as of the date received, if the payment
is (1) received by 2 p.m. (Eastern Time); (2) received at the
address shown in the upper left-hand comer of the front of
your monthly statement: (3) paid with a check drawn in U.S.
dollars on a U.S. financial institution ora US. dollar money
order: and (a) sent in the return envelope with only the top
portion of your statement accompanying it. Payments
received after Z p.m, 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.
Now 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 new transactions) with Iowa APRs before balances
with higher APRs. This will result in new balances with lower
APRs Isuch as those with promotional APR offers) being paid
D.
0V2012006 15:26 FIA CARD SERVICES i 912672952844 N0.873 9008
belore any other existing ba{anCZs
Promise to Pa lies to All Persons
All persons who inisiaiIV or subsequerrtiv request, accept.
cir use he for anv total outstanding balanlce.aWe mast her
guaraee.
responsible on who is responsible to pa±
to release from liability any pers
any total outstanding balance. until all of the cards. access
checks, and Other credit devices outstanding under the
or
account have bees returned to us and any such person
to u5
persons repays us the total outstanding balance owed
at any time under the terms of this Agreement.
R 1112, ault
you will be in default of this Agree"" eat Due by itsiPtaymer
make any rMlyoud'rotal Minimum balance exceeds your creel.
Due Bate; (2) Your total outstanding
limit; or (3) you fail to abide by any Other term of this Agreement. Solely for the purposes of determining eligibility
and premium payment obligations for the optionsl cretin
insurance purchased through MBNA. You will be deemed in
default or delinquent if you fail to make a payment within 9t
days of your Payment Due Date. our failure to exercise any
our rights when se you default doe-, not mean that those rights upon later delault? are
unable to exerd
When We iii jIT Unmledl& Pa tnet
if you are in default, we can rsAuireirrimedia a byme t
Df your total outstanding balance and. unles sec under th.
k
applicable law and except as otherwise preentettrt we can
Arfiirralioa and Litigariarr her costs weSnI in any coliectic
also require You to pay fees if we ref,
proceeding, as well as reasonable attorrieywho is not our
your account for collection to an attorney
salaried emPloyee.
other Pa ert Terms
we on eocept late payments, pattfal payments. Or PAY-
ments with any restrictive writing without losing any of ou
rights under this Agreement. This means that no paymen+
including those marked with., Paid in full" or with any oft
restrictive words, shall operatro
9 as an accord val of one f our senor offii,
without the prior written aP? check to make a payment. 1
You may not use a postd
you do a PaYrrint cheer we may elect to honor
postdate
upon Presentment or return it unctedited to the pawn w'
presented it, without, in either case, waiting for the date
shown on the check. We are liable to of the you (Or an ?? to
expense incurred by you arising
Pa meat Hol& 1 s
We may allow you, from time to time, to omit a month.
payment. We will notify you when this option is availabl
you omit a payment, Finance charges and any applicable
will accrue on your account in accordance with this
Agreement. You must resume making your Total MiY k
Payment Due each month following a paym
Transactions Made in Fo ' n Curren(
if you make a transaction in a foreign ruvrerI the tran,
will be converted by Visa international or MMeerCa into a
International, depending On which card you
dollar amount in accordance with the operating regufatit
conversion procedures in effect at the time that the trans
is processed. Currently, those regulations and procedut
provide that the currency conversion rate to be used is
?r
071/20/2006 15:26 FIR CARD SERVICES 4 912672952844 N0.873 D009
r
t
i
c
r
(I I a wholesale market rate or (2) a govemmem-mandated
rate in effect one day prior to the processing date. increased
by one percent in each rase. visa or MasterCard retains this
one percent at compensation for performing the currency
conversion service. The currency conversion rate in effect on
the processing date may differ from the rate in effect on the
transaction date or the posting date.
IRM 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 statement
reflects a single billing cycle.
Account Fees and Charges
Account Feels The following fees, which are set forth in your
Required Federal Disclosures or Initial Disclosure, am charged
as Purchases in the billing cycle in which the fees acute:
(1I a Late Fee if the Total Minimum Payment Due shown on
your monthly statement is not received by u5 on or before its
Payment Due Date:
(2) an Overlimit Fee if your New Balance Total exceeds your.
credit limit on the last day of a billing cycle. even if fees or
finance charges charged by us cause your New Balance
Total to exceed your credit limit; an ovedimit Fee is
charged to your account as of the day in the billing cycle
that the total outstanding balance on your account exceeds
your credit limit:
(3) a Returned Payment Fee if a payment on your account is
returned for insufficient funds or for any other reason, even if
it is paid upon subsequent presentment;
(4) a Returned Cash Advance Check fee if we return an access
check unpaid for any reason, even if the access check is paid
upon subsequent presentment:
(5) a Copy Fee for each copy of a monthly statement or sales
draft, escept that the six most recent monthly statements and
six sales drafts will be provided for free: and
(6) an Annual Fee if your account is open or if you maintain
an account balance, whether you have active charging privi-
leges or not.
Abaxdomed-PrvpeM Charges; Unless prohibited by
applicable law, we will charge your account, as a Purchase. for
any costs incurred by us associated with complying with state
abandoned-property laws.
Please review your Required Federal Disclosures or initial
Disclosure for additional fees and charges that may apply to
your account.
Ben!ft!
We may offer you certain benefits and setvicas with your
account. Unless expressly made a part of this Agreement. any
such benefits or services are not a part of this Agreement but
are subject to the tam and restrictions outfitted to the benefits
brosdwrie and other official documents provided to you from
time to time by or on behalf of MBNA America. We may
adjust, add, or delete benefits and services at any time and
without notice to you.
Rerft!Ml to Honor Your Amunt
We are not liable for any refusal to honor your account.
This can include a refusal to hover your card or amount number
or any check written on your account. We are not liable for
any retention of your card by us. any other bank, or any
provider of goods or services.
9r
07/20/2006 15:26 FIR CARD SERVICES 4 912672952844 NO.873 D010
We May Suspend or Close Your Actouni
We may suspend or close your account or otherwise term:
your right to use your account. we may do this at any time a
for any reason. Your obligations under this Agreement contr
even after we have done this. You must destroy all cards. ac,
checks, and other credit devices on the account when we rec•
that you do so
You May Close Your Account
You may close your account by notifying us in writing C
telephone and destroying all cards. access checks, and or?:
credit devices an the account. Your obligations under thni
Agreement continue even after you have done this.
Transactions After Your Account Is CIosc
When your account is dosed, you must contact anyone
authorised to charge transactions to your account, such as
Internet service providers, heahh clubs, or insurance COmpan
These transaaions may continue to be charged to your
account until you change the billing. Also, if we believe yt
have authorized a transaction or are attempting to use y0L
aaount after you have requested to close the account, we
may allow the transaction to be charged to your account.
We May Ainemd This rillsr3llnent
We may amend this Agreement at any time. We may
amend it by adding, deleting, or changing provisions of thi
Agreement. When we amend this Agreement, we will comr
with the applicable notice requirements of federal and
Delaware law that are in effect at that time. If an amendm,
gives you the opportunity to relea the change, and if you
reject the change in the manner provided in such amend-
ment. we may terminate your right to receive credit and m6
ask you to return all credit devices as a condition of your
rejection. The amended Agreement (including any higher-r
or other higher charges or fees) will apply to the total out-
standing balance, including the balance existing before the
amendment became effective. We may replace your card w
another card at anytime,
We Ma SeQ Your Account
We may at any time, and without notice to you, sell. assi.
or transfer your account, any sums due on your account, the
Agreement, or our rights or obligations under your account
this Agreement to any person or entity. The person ar entit•
to whom we make any such sale, assignment or transfer sha
be entitled to all of our rights and/or obligations under this
Agreement to the extent sold, assigned or transferred.
Your Credit Limit
Your credit limit is disclosed to you when you receive yot
card and, generally, on each monthly statement. We may
change your credit limit from time to time,
The amount shown on your monthly statement as Cash L,
Credit Available does not take into account any Purchases,
Cash Advances, finance charges, fees, any other transaction!
or credits that post to your account after the Closing Date o
that monthly statement. Such transactions could result in
your credit limit being exceeded and result in the assessmei
of Overlimit Fees.
What we may Do if You Attempt to
Exceed Your Credit Limit
The total outstanding balance on your account plus authoriza•
pons at any time must not be more than your credit limit. If yc
S.
O?/20/2006 15:26 FIA CARD SERVICES 4 912672952844
N0.873 D011
attempt a transaction that results in your total outstanding bL
ance (plus authorizations) exceeding your credit limit. we ma%
(I i permit the transaction without raising your credit limit. I,
permit the transaction and treat the amount of the transactio
that is more than the credit limit as immediately due: or 131
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 refuse:
if we refuse to permit a check cash Advance or Balance
Transfer, we may do so by advising the person presenting the
Check Cash Advance or Balance Transfer that credit has been
refused, that there are insufficient funds to pay the Check Cas
Advance or 8alanae Transfer, or in any other manner.
If we have previously permitted you to exceed your credit
3 limit, it does not man that we will permit you to exceed yot
credit limit again. If we decide to permit you to exceed your
credit limit, we may charge an ovedimit Fee as provided in
this Agreement,
UnauthorhO Use Your Card
please notify as immediately of the loss, theft, or possible
unauthorized use of your account at 1-800-789-6701.
t You Must Notifiy Us When You Change
Your Address
we strive to keep accurate records for your benefit and
! ours. The post office and others may notify us of s change cc
your address. when you change your address, you must notil
us promptly of your new address,
What Law APPUes
This Agreement is made in Delaware, and we extend credi:
to you from Delaware. This Agreement is governed by the
1 ` laws of the State of Delaware (without regard to its conflict o
laws principles{ and by any applicable federal laws,
1 of 1#gjreeiirteiltt Are
The Provisions o This
1 If any provision of this Agreement is found to be invalid,
the remaining 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 exevdsg
those rights later.
Arbitration and Litigation
This Arbitration and Litigation provision applies to you.
I unless you were given the opportunity to reject the Arbitration
and Litigation provisions and you did so *40 them, jn the
' manner and tirneframe required. If you did rood effectively
such a provision, you agreed that any litigation brought by yo!
against us regarding this account or this Agreement shall 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 against the employees, agents. or assigns of the
other, arising from or relating in any way to this Agreement o
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), includinn
claims regarding the applicability of this Arbitration and
Litigation section or the validity of the entire Agreement of
any prior Agreement, shall be resolved by binding arbitration
The arbitration shell be conducted by the National Arbitratior
ilk
07/20/2006 15:26 FIA CARD SERVICES -> 912672952844 NO.873 0012
Forum !' N.4F'I, under the Code of Procedure it effect at the om
the Claim is filed. Rules and forms of the National Arbtt atrnr.
Forum may be obtained and Claims may be filed at any Natiom?
Arbitration Forum office. www orb-for itn.gom. or P.O. Box 5019'.
Minneapolis, Minnesota 55405, telephone I-800-474-2371
if the NAF is unable or unwilling to act as arbitrator. we may
substitute another nationally recognized, independent arbi-
tration organization that uses a similar code of procedure.
At your written request. we will advance any arbitration filine
fee, or administrative and hearing fees that you are required
to pay to pursue a Claim in arbitration. The arbitrator will
decide who will be ultimately responsible for paying those
fees. In no event will you be required to reimburse us for an•
arbitration filing. administrative, or hearing fees in an amour
greater than what your court casts would have been it 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 o ree-
merit is made pursuant to a transaction involving Interstate
commerce and shall be govemsd by the Federal Arbitration
Ad, 9 U.S.C. ff 1-I6 ('FAA"). lodgment upon any arbitration
award may be entered in any court having iurisdiction. The
arbitrator shall follow existing substantive law to the extent
consistent with the FAA and applicable statutes of limitatiom
and shall honor any claims or privilege recognized by law. if
any party requests, the arbitrator shall write an opinion con-
taining the reasons for the award.
No Claim submitted to arbitration is heard by a jury, and
no claim may be brought as a class action or as 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. 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 banltrW y by you. or
sale of the debt by us.
For the purposes of this Arbitration and Litigation section.
"we and 'us' means MBNA America Bank, NA, its parent,
subsidiaries, affiliates, licensees, predecessors, successors,
assigns, any purchaser of your account, and ail of their officers
directors, employees, agents, and assigns or any and all of
them. Additionally, "we" or 'us- shall mean any third party
providing benefits. services, or products in connection with
the account (including but not limited to credit bureaus. mer
chants that accept any credit device rued 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 codefendant in any Claim you assert
against us.
If any part of this Arbitration and Litigation section is
found to be invalid or unenforceable under any law or statute
consistent with the FAA, the remainder of this Arbitration ant
Litigation section shall be enforceable without regard to sucl
invalidity or unenforceability.
THE RESULT OF THIS ARBITRATION AGREEMENT IS
THAT, EXCEPT AS PROVIDED ABOVE, CLAIMS CANNOT BE
LITIGATED IN COURT, INCLUDING SOME CLAIMS THAT
COULD HAVE BEEN TRIED BEFORE A JURY, AS CLASS
ACTIONS. OR AS PRIVATE ATTORNEY GENERAL ACTIONS.
10
071/20/2006 15:26 FIA CARD SERVICES 3 912672952844 NO.873 P013
CREDIT INSURANCE BENEFITS,
LIMITATIONS, COSTS S EXCLUSIONS
CONSUMER PROTIXT1ON DISCLOSURES
CREDrr INSURANCE IS: NOT A DEPOSIT, NOT FDIC-
INSURED: NOT INSURED BY ANY FEDERAL GOVER14MENT
AGENCIF, AND NOT GUARANTEED BY THE BANiL
iPuRCHASE OF CREDIT INSURANCE IS NOT A CONDITION
OF OBTAINING CREp17- IF COVERAGE IS DESIRED, IT
MAYBE PUB2111 E ELSEWHEIRIL
tMdkIlliffiam pays your minimum monthly payment'
up to your balance on the date of loss snot to exceed $25,000,
except disability in MN), until you return to work, • if you are
involuntarily unemployed. SCI& disabled, or if you or your
spouse takes covered family leave. Credit Insurance also
pays your insured outstanding balance up to the least of your
outstanding balance, your credit limit (not AL, AZ, AR, DE,
DC, ID, IL. W LA MD. MN, MS, NV, ND, OH. OK. R). SD, Vr.
WA. WV fs WY). or $25.000 if you die.
QWh1 C One insured per account (insured must be the
primary cardholder or a co-applicant. authorized users are not
eligible). under age 66170 in AZ, NV & VA; 71 in FL, GA, Ml,
MO & OK: 72 in NMI. Your coverage ends at these same ages
(except family leave in AZ, FL & SD 1s unemployment). When
enrolled, certificates will be mailed explaining yout coverage
& effective date. In MN, unemployment coverage is effective
61 days from your certificate effective date. For unemployment
or family leave benefits, you must be gainfully employed
working at least 30 hrywk (not self-employed or an independent
contractor) for 90 consecutive days before the date of loss
(CO - before application date), (PA • on the date of loss).
(TX - before coverage effective date for unemployment).
Employees of professional corporations may be eligible.
Credit Insurance covers. your
death; involuntary unemployment due to Job loss, general
strike, unionized labor dispute, or lockout; total disability due
to sickness or injury if you are unable to perform the material
& substantial duties of your job (or any job after 12 mos, in
PA; 18 mos. in AL, AZ. AR, CA, DE. DC, GA. Hi, ID, IL, ]A, KS,
1.A. MD. MN, M5, NV. NI. N.D. OH. OK. Rl. 50. TN. VT, WA, W
WI & WY); your or your spouse's unpaid leave of absence
from employment due to care of your newborn or newly adopted
child or an incapacitated immediate family member (must be
spouse, child, stepchild or parent in AK): mandatory recall to
active military duty: iury duty (except in AK): or residence in
a federally declared disaster area. Loss (not death) must
continue at least 30 days before benefits begin. In NY, for
strikes, unionized labor disputes S lockouts, you must be
unemployed for 7 consecutive weeks 6 qualify for state unem•
ployment benefits before benefits begin. A daily benefit is
paid for each day of loss over 30 days for unemployment in
NY & PA, and disability in CA. Cr. GA NY, MI. PA. RI & $C.
You may cancel this coverage at any time. if canceled within
the first 30 days of comrage, all premiums will be refunded.
Z1&b ai W- Life: suicide in the first 6 months of coverage
(not MD & MO). Involuntary Unemployment; retirement,
resignation, voluntary forfeiture of income or job low due to
willful or criminal misconduct, disability, strikes in IL, military
discharge in NY & normal seasonal unemployment in TX
Disability. normal pregnancy or childbirth Inot CA, MA S NV).
intentionally self-inflicted Injuries fnot MD), or a pre-existing
medical condition during first 6 months of coverage (not NJ I.
Family leave benefits are not paid if you are eligible for or
receiving unemployment benefits or are disabled.
071/20/2006 15:26 FIA CARD SERVICES 4 912672952844 NO.873 9014
This is only a brief description of coverage, and coverages
vary by state. Please refer to your certificates for a full
explanation of coverage.
QWS r
Costs apply to Life ILI. Disability (D), Unemployment (U) 6
Family Leave IF): AL 54.5c: AK 7&; AZ 99.9C; AR 99c: CA
8990: CO 50.66C: Cr 42.89c; DE 99.9c: DC 99.9c: FL 89t; CA
90.8c: Hl 89.91c: ID 99.5c IL 8.6c, D 16.9t, U 54c. F 2001; IL
80.97c; IN 96c: IA 97.Se (L 7.2c. D 16.60, U 54C. F 20c); KS
85,47C; KY 97AC; LA 99.93c; ME 53.05c; MD 79.74c; MA 15.7c
MI 45.7c; MN 31.47c; MS 925e; MO 61.1c: MT 91.9c: NE
95.&; NV 99,87c; NH 95C: NI 97C; NM 58,9c: NY 525c tL 8.8c
D 26,80, U 16.9e): NC 71.30; ND 94.97e; OH 99.9e; OK 97.47e:
OR 80.8c; PA 38. Ic: PR 99C: RI 99-&; SC 741.3e; SD 99,9c; TN
92.5c; TX 3333 IL 4,8C, D 12.91. U 16c); UT 90.44c; VT 34.92c
(L 6.68e. D 12.24c. F 16c 1; VA 84t (L 6,1t, D 8.9c, U 49C, F
20c); WA 89.39c; WV 995c: WI 93.6c (L 5.7c. D 8.9c. U 59c. F
20c): WY 99.7c,
AMMLWft involuntary unemployment is not available it
MA or VT. Family Leave is not available in AL. CP, MA, MD.
MN, NM, NY. PA, or TX.
Involuntary
Unemployment: American Security&01(5/85). L01 NY(3/931,
AS LOI T&I 1/991, LOIC4P-KS(2/961. LOIC4P-CRS-ME(5/851
and LOIC-112: Standard Guaranty/SG LOI (51851 INK only!.
Life S Disability: Union Security Life/L +Z, L-S-G in AL, AZ,
AR, DE, DC. ID. IL, IA. KS, LA. MD, MN. MS. NV, ND, OH, OK.
RI, SD. VT, WA. WV & WY; Standard Guaranty Life (TX only)/
LA-Z(8142)(3,53RAf, First Fortis Life (NY Life only)/NYLM0013
American security (NY Disability only)/W-5-A, Fortis
Insurance (ME on)y)AJ-X-A, Family Leave. American
Securuy/FLP 141'971, FLP-FL021971 in FL, FLP-NC (3/98) in NC.
FLP-OK(4197) in OK, FLP-VA(2/98) in VA, FL-IP(AZ)17/98) in
AZ. FL-IP14/97) in IL & IN. FL-IP•KS (12197) in K$, FLIP-MF
(09) in ME; FL1P•WY(4/97) in WY; Standard Guarenty(FLP
(4197) in NH: Union Security LiWFLP-VT(4197) in VT, Solicitin:
amts for Mississippi and Florida are Charles M. Gordon and
Pamela Curtis respectively.
The creditor may receive compensation in connection with
this offer.
It is at crime to provide false or misleading information to an
insurer for the purpose of defrauding the insurer or any other
person. Perwhies indude imprisonment and/or firma. in addition
an insurer may deny insurance benefits if false information
materially related to a claim was provided by the applicant.
•Less past due and aver credit limit amounts. In MI, cover-
age pays 5% of the balance on your date of disability up to
SI250. In OR, coverage pays the greater of Vieth of the bal-
ance or the current minimum payment due on your date of
loss, in NY S PA, coverage pays the minimum payment due
on your date of loss, in TX, coverage pays the greater of 6% o
your insured outstanding balance on your date of unemploy-
ment or your minimum monthly payment.
•'The cumber of monthly benefit payments will not exceed 9
for family leave: 12 for unemployment in Al.. AK, CT. IL, MI. MN
MO, NM, NC, NY, PK SC & TX; 12 for disability in AY, CA, CT,
FL, KY, MA, MO. MT. NE, NH, NM, NC. OR, SC. Tf 6 VA.
NY, NI & 7% OW Tb purchase coverages sepsretelh
write to Assurant Group, P. 0. Box 50355, Atlanta. GA 30302
Applications wf11 be seat to you.
07.'20/2006 15:26 FIR CARD SERVICES 4 912672952844 NO.873 D015
J
.1
2NMI MBNAULOI (MBNA • UD/Uncapped LOVFL)
25000 DISC-101
MSNA America Bank, NA, is the exclusive Issuer and
administrator of Plag am Plus credit card accounts.
MBNA America@ and Platinum Plus@ are service marks of
MONA Amedo Bank, N.A.
b 2001 MBNA America Bank, N.A.
NEMO (Revised 4/2001)
VERIFICATION
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 JEFFERY
FELTENBERGER owes the balance of $11,535.41 to CACV OF
COLORADO, LLC. on previously submitted invoices, which balance is due and
unpaid as if 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
unworn falsification to authorities.
r???
By
MAR w µ 2310
Dated:
LANI
Authorized Represent""
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson -'-'- . - ~-,~~
_,
' S.V. it _. ~ ,, ...
Shen ~~~~~a,~ ct ~~„ ~u,~~.~~~~~
Jody S Smith n ~ c , -
Chief Deputy LU ~ ~., k.~ "tC ~ =~ t" , ~ ~~ v
Edward L Schorpp ~, _ _. -. , ~,,.
tom..;:: ;: _... ~ -
Solicitor ~'~' ~ ~ ~ ~'~`' ~~`~~
r~ ~ ~.~. .
CACV of Colorado, LLC
Case Number
vs.
Jeffery Feltenberger 2010-2354
SHERIFF'S RETURN OF SERVICE
04/13/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Jeffery Feltenberger, but was unable to locate him in
his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant
Jeffery Feltenberger. Current residents of 432 W. Shady Lane, Enola, PA 17025 advised Deputies they
have resided at this location for three years and do not know the defendant.
SHERIFF COST: $46.50
April 13, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
;c; GourcySuit~ Shenff Te'es>s:ft, Inc.
of cu4,
lnavid D. B ueCC e Renee R Simpson
2 f
prothonotary , y 1st (Deputy lnrothonotary
u \9 .". v
7irkS. Sohonage, ESQ \
.41‘' a� ,_ '= � Irene E. Morrow
Solicitor \,a so . 2 Deputy Prothonotary
Office of the cprotFionotary
CumberCand County, �ennsy(vania
/D "235 y CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
PA R.C.P.230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 • Carfisfe, cP)4 17013 • (717)240-6195 • cFax(717)240-6573