HomeMy WebLinkAbout10-5521'*y
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A. T
Plaintiff No: (Q - ?? ?1V1? 1°?•
vs
KELLY A RUGH
COMPLAINT IN CIVIL ACTION
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
08352161 C J Pit SJS
4Ra.oo PA ATT-1
4%tp 08 7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs.
KELLY A RUGH
Defendant
Civil Action No
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or
for any other claim or relief requested by the plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff, CHASE BANK USA, N.A. is a corporation with offices at
3700 WISEMAN BLVD. SAN ANTONIO , TX 78251 .
2. Defendant , is adult individual(s) residing at the address listed
below:
KELLY A RUGH
1218 PINE RD
CARLISLE, PA 17015
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXX9799
4. Defendant made use of said credit card and has a current balance
due of $17842.77
5. Defendant is in default of the terms of the Cardholder Agreement
having not made monthly payments to Plaintiff thereby rendering the
entire balance immediately due and payable.
6. Plaintiff avers that the Cardholder Agreement between the parties
provides that Defendant will pay Plaintiff's attorneys' fees.
7. Plaintiff avers that such attorneys' fees will amount to $300.00 .
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the principal balance, and
accrued interest or any part thereof to Plaintiff.
Wherefore, the Plaintiff prays for judgment against Defendant ,
KELLY A RUGH , INDIVIDUALLY , the amount of $17842.77 with continuing
interest thereon at the statutory rate of 6.000% per annum from August
06, 2010 , plus attorneys fees of $300.00 and costs.
James u warmnrouL,gznzq
WELT , WEINBERG & REIS CO., L.P.A.
436 Se en h Avenue, Suite 1400
08352161 C J Pit SJS Pitts rg , PA 15219
(412) 43 -7955
FAX: 412 338-71.30
This law firm is a debt collector attem i to collect this debt for
our client and any information obtained w' 1 be used for that purpose.
................... .
New Balance Ainlmum Payment
Payment Due Date
03122!'10 517.657.01 51.20100 $1,6$7.00
Account number: 9799
Make your chock DaYaole lo:
,tv Chase Card
YW. Please write -mou amoun tto
nctoSed.
New address or e.maA'+ Pnnl on back.
97990016870001765701000000000000001
15198Ex9056100
KELLY 218 PINE ROH
CARLISLE PA 17015.9319
LrrIILr4{{I4.4„rIId,LI,I,,,,{Lr,.ll{,L,.,rl{14,LJdrl
I,r.IIIJ4rl..I,hrlr,ILIrIrL4rrilrlrl„.II„Idr,rllr,ILJ
CAROMEMBER SERVICE
PO BOX 15153
WILMINGTON DE 19886-5153
1-50001602" 'WOUNM?9 799 2lta
8352161
8352161
CHASEFREEDOM- Manage your ac-ord online: Additional contact informatlon
1w_xw chase con>Irn, ircards cpnvemently boated on reverse side
ACCOUNT SUMMARY
Account Number: 9799
Previous Batalxe 517,347.13
+539.00
Foes Charged
interest Charged _ ?S -270'88
New Balance S17,G57.01
Opening(Closing Date 01!26110 -02125!10
517,500
Total Credit Line
Available Credit So
517,500
Cash Access Line SO
Available for Cash
PAYMENT INFORMATION S17,65701
l
New BaN 03125:110
Payment Due Date St 68' 00
Minimum Payment Due
Late Payment warning: If we do not receive gout minimum
payment by the date listed above. you may have to pay up to a
$39.00 late fee and your APRs will be subject to increase to a
maximum Penalty APR of 29.99%.
Minimum Payment Warning: It you make only the minimum
payment each por"lod, you will pay snore in interest and it will take
you longer to pay off your balance. Por example. --
It you make no you wJl peY oft the And you will end up
an estimated
i
addiliortal charges balance shown on ng
pay
.
total of
using this card end this statement in
.
.
each month you about•°
pay... -
Only the minimum 37 years 544.109
payment ...-
$$ti 3 years 523.100
(Savings=521,009)
ou would like Information about credit counseling servtces..111
If
y
1.866-797.2885.
The charge privileges on your credit card account have been revoked, You no longer have the ability to use your credit card
800-955.8030 (coned 1.102.594.6200) today.
ll 1
-
account for purchases. We can help you get back on track. Ca
Imporlard message: You Are Ovedimil! payment that mclutles the ove,1-1t, Amount to bring the
You sheuld make, a
credit line
.
your statement balance exceeds your
balance under your credit line.
err?atueRV
ULTIMATE tttvlti+RDS
CHASE FREED
_
S0,00
Previous rewards balance 5000
Rewards earned mt purchases 50.00
Bonus rewards from Ultimate Rewards Travel $0
00
.
Bonus rewards earned at Ultimate Rewards Mall S45.18
Rewards unavailable for redemption S000
Current rewards balance
Your Chase Freedom credit card allows you to earn Unlimited Cash Back Rewards With No Explratlon! You earna lull l% cash
when you
cast' back
rn even more! Earn up to an additional
d
el n
back on ALL of your purchases with ongoing opporlunilios to ea
Rewards
for
car
s
8
shop online through the U!Ilmatlineatrdwwwaohase. op ulematerewards or caaus at (800) G 0-5076.
merchandise. To redeem, go
ACCOUNT ACTIVITY
Date of S Amount
Merchant Hama or Transaction Oescriplion _
Transaction
-x900
-
L' FEE 539,00
01119:,
TOTAL FEL-S FOP T?11S PERIOD
INTER_E$T GHAItGED.,,., - 25427
021,15 PURCHASE tNTEREST CHARGE 16 61
02125 BALANCE TRANSFER INTEREST CHARGE 5270.88
TOTAL INTEREST FOR THIS PERIOD
A 11619 ,OpM%Wa3a1 1ti190i
056
6
1
000 Y 9 25 '"?)25 Pagel o12 05606 AU 000
???yyy
00000, rtS33336oa
.1, 0122 INS 13470 6
,,arc yvrsay-eea+:ss>y
Statement Dale: 0V26 799
Account Number'.
Page, 2 of 2
';,2010TolalacYeardo?Datu
Total fees charged in 2010 539.00
Total Inlerest chargetl in 2010 5270.88
r•1014ate totals Wm-'. charges minus any mfunds
yea
t apptled to your account on or after January 31, 2010.
INTEREST CHARGES
Your Annual Percentage Rate (APR)is the annual interest rate on your account. gccrued
Annual Balance
Interest
ect To
Percentage Rate (APR) Sub
s Interest
Charges
Charge
Balance
Rate
Interest
31 Days In Cycle
Type
$16,414.17 $254.27
24% (v}
18 50.W
SOW
.
Purchases
19,24% (v) $0,00 5000
Cash Advances
072.45 S76.61
S1 $000
,
1624% (v)
Balance transfer
(v) = Variable Rate
e ualecl to Interest Rate, Annu
a cu
al Renewal Notice.
Plea
se
lion as pPt nc
Yours Account unt se i
0.aM nC
rma ion
o
mpo
other
Purchases.
Interest on
A ofd
How 8352161
8352161
000 Y 0 25 lwb25 Gu9o 2 v12 056N 6 M 11619 06610000080001161902
X 0000001 F53333808
CMAQW2 fees and finance "barges, and making sure it
of your account balance, linne if your any account reem
ent We may, but
??? ?t remains below charge youan o f erlindltoa its described in this over ag ur "red t line for any
g 6 eason,we m ay o over your credit line. You must pay any
to, authori charges that y linu e , and you must pay Lis immediately if ask y
Cardrernber A re
runt over your cre it uu to. This
are not required our account. including any balance over your
am
ACCEPTANCE CF THIS AGREEMENT ayr
This agreement governs your credit card account withUs fete renced on the ca, ca rne aining the card Iortltfs a ccount. Any use utyOttr account is coveted by this agreomiseement- to cre
se read the entie agreement and keep it for your records. You authorize us to paY At
contlOr and charge your a"countfor all transactions mads on your accouolinaYOU nctor charges.
Pay us for all transactions made On your en}tarand individually, is r sponsible for paying 10
Pleach of you, tog you, We may require that inn
If e this is a joint account.
alt amounts owed, even if the account i5 used by only one of yo this agreement m'
it
you pay the lull amount owed without firs[ asking the ,her person(s) to paY. a
ed by card ywhenyoulocal"' it. Yolot any u willbeteoQSchavenifyoudon'I In
you use your account ou will be bound by this agreement
it s you e or an henyone back of authorizyour
plea
Sign your card. Whetheryou Use your ar,count off ot, y on
unless you cancel your account within 30 days alter receiving your card and you h Ae a
j3prk US.,
not used your account for any purpose.
"us' and'our maaour"i and 'yours" MA, [a
an all
Throughout this agreement, the words -we
the issuer of your credit cart and account. The words you Y O
reement . iYOU billing , Y g the personwhoapplied g
o"fespunsibleiorcomplYhngwiththisay statements, as well as any o
pers d
for the account and the person to whont we address o
personwhoagreestobelfable Onthea,CDuf),Theword"card" means one or morerards
or other access devices, such as account numbers, that we have issued to permit you
to obtain credit under this agreement. t
USING YDUR ACCOUNT
Your account is a cunsumvr account and shalt be used only for personal, am[ y U t
ee or1Iisrequiredbylaw,we will not be responsible
householdpurpDees. Unless we agr ,,d throuh' use of ,of account. YOU ise
urch
ased
or l prom se 1o u se your account Doty for valid andlaw ultra sacs ors. For example internee Ih8tVOU
gambling may be illegal in some places. It is not our fesponsibilityto make sure sable (Of
rmissfble transactions, and you will remain respo `dement
use your account only for Pe ,
paying for a transaction oven itis not permissible o[ contemplated under th his a9
Types of TransaetieA5: pay for goods or services.
nsfer chiles as a
.
purchases: You may use your card h advance checks or balance t as tree tocheyckour or account,
Checks: We may provide you cass
wayto ,,Your accoun t.Wealsorefer totherein,,isagree
e
YOU may use a check to pa y for goods or services, t.transfer balance
other uses we allow. But You is may not use these checks to transfer balanOnly ces 10
ith us or any of out related companies. Ch t s
Or for n the chos h advance checks
this account Irom echo, accoun w ck. Ca
person whose name is printed on doe check may pig
are treated as cash advances and balance or[any oflar hwekmake[orYOU'Wemaytruat
transfers except as noted in this ag nt
checks that we call conveniencechecksasbale ncetransterchetks.However, ectto the ltr checks
,bat sh ll conv advances, maYa h treated as clash aJvancestand assessod cas jh ad ancera es
and lees. balances Irumother accounts or Soars with other
Balance Tra nslers: You may transfer
creoilcardissuersorotherlenderstothis0ccounLorother balance lthuso ow.
But you may not Iransler balancas to this account from other accuntswilh us or any nsfo of our related companies. 11 a portion faaparatio alsbaLnce atrans rler up rto iy l your "available
available credit line, we may p
credit line. et cash from automatic teller ma chines, or
Cash Advances! You may use YoUr card W 4
Or [o obtain lottery
tery
Irom financial institutions accepting the card; or to obtain trevelm checks, o t
wire lrnnslr.rs or simila is r cash-like
d a PBV'
or a for sh si-likemilar charges; betting transactions- o
currency, money orders,
meet on Yovr behalf and bit(i;""the payment
fig chips, race track W89
tickets, casino gami
may also use a third party service to make a pay
to this account.
OVCrdrafl Advances: $I yet) have an eliyibls shacking account with one la our relate ank b
11
d
over ant an
bank, ' ona, anou may aB o11i a "she"king aoccou t UnderatheOterr s DI this agree
your checking account agreement. 'fi We divide me Biding cycle: InorderStagm5nageYour elyonetmonhinlength.[Foroacihcalendarmonth.
cycles" Cacti billing cy statement
each ling Cycle that eds at Morrill w112111 r ornnot there is a bill nIy will roil a calend
your
Cycle I eill have
for that billing cycle. our account, that person will be an
Authorized Users: 11 you allow someone to use y
authorized User, You may request an additional card for use by an authorized user o
this account may appear on the credit report of that authorized
youracCDUr1I IdYOU so,
user. You should think carathalt peelson toluso rho account as yoiu can. Youhwilleremafi
DOr Paying t all according
because you are allowing charges acc
och card issued ony to the tebmsf of hisuagree font. This includes your responsibility
on your account made by an authorized user. ermission 1o use your account. It
I cards with a dillerN also
You must notify us to terminate an authorized users P cards, checks or any efer
you notify us.we may close the account and/of issue a new card o
ove account number. You eu? j?count from that authorized user.
1?epur? on your billing statements. We may alsoareterito t of
rerlilitnt e credit line appears
line as a credit limit, Your billing statement may also show that onlah ail that us, i your ereditlina may be used lot cash advances, Cash advent
your creditlm c cassh odvancu
checks, are charged egainstthe cash advance p
transactions are charged against your credit fine. You are responsible lot keep'ng track
page 7 of 6
ailment apPlies to 311Y balance on y
dit line.
our discretion. we mayin"ruasa.reduce,mcancel it the cash do trance
rtion of your credit line, at any time. Howevever, it you have asked us not to do iga we
I aIf Oct your obligation
notinerease your credit Sine. A change to Your "redo tine will not
pay us.
ea us.nal Transactions: International transactions include any transectiun'.hut you
ka a a foreign currency orft,at 'IOU ntakv outside of the United States of America even
it is made in U.S. dollars. if you make a transaction in a foreign currency, Visa
ternational Of iv ese e five currency convlernc Will Convert sion procedu estl The rexchantge r+ate each
ollarsbyusing P
tify uses to convert currency is a rate that it selacts either from the range n rates
its in (13 vailabie in the w Olesa theUmate y hark etspeci ve uenfttyb"Sell creceives)1e orahtl e
Iii may very' hcable rocessin
overmneni-mandate gdate. Therate ineHect
dra ingdaydife P
n the applicable processng datee may differ front tiro rate al3the % date you . doll your card
racco rtn119fi oywhether that lrensticitionwas originasymlade in U.St.
t any international
tailors or was made in another currency and converted to U.S. dollars by Visa or
idiu C cal MasterCard. In either7hUesahme oproclebs and chaeges [nay DV YI itra+ Y nternational
o us by that entity.
,,,,action is reversed.
Ratusal to Authorize Transacuous:VJe may, but are nut required to, dcclina a lransacuon
ur accountfor any of the following reas
On Yo ons:
because of operational considerations.
because your accomtt is in default,
it we suspect lraudule
in our discr etion, for antny or unlawlvl reason?irwty fly.
We are not responsible for any losses if a transaction on your account is Declined or
any reason, either by us or a third pang, even it you have sufficient credit available.
For online transactions, we may require that you register your account with an
it we want you to register. It you
onwine ltlransanolilyctiyouons.
authorization system that we relyouay[.r Weli
do not register, we may decline our r Refusal to Pay Cn a kst e may re ieVw yo rrtaccount to decide whe haricot aruthorize 11 1,11
a check for pay re Oct and return Unpaid a Check for any reason,
check. We May, but arc not required to, 1
including the following examples;
We or one of our related companies is the payee on the "beck.
Ybur credit line or cash advance potion of your credit line has been exceeded, or would
be exceeded 11 we paid the check.
The ehockis post dated check is paid, resuking in another shack being
• cra
-dated. if a post-
returned or not paid, we are not responsible,
ed the check alter the date specified on it.
You have us
you are in default ur would be if w0 paid [I'll check.
Lust or Stolen Cards, Cheeps or Account Numbers; If any Card, check. accOUnt number som or ,her means to access your account is lost
U must no rid Y suattionce by callingdtile
may use them withor, your permission, y
Gardmember Service telephone number shown on your card or hitting statement. Do not er of other notify m
use our account eans to access yourraccount is found or relurnod rWe may tern count Hate ors b Pend your
ratify us of any loss, theft or unauthorized use related no your
credit privileges when you
account.
you may be liable it there is unautheri"d Use of your aCCUUnt from which you re aivu
no benefit, but you will not be liable for more than 550.00 of such transactions, and you
will not be liable for any such transactions made after you nolily us of the loss. Irish or
anauthorized use. HowEve,, you must identity lot us the unauthorized "Barges Iron wheel;
you received no benefit.
Wemayregos,eyoutoprovidcusinlornVaGhncertain nProcedures it) connection with cut
We inay also require you to comply
investigation.
PAYMENTS statement and accompanying envelops include
Payment Instructions: Your billing payments and sets forth the dale and time by
instructions YOU must follow foking which we must receive the payment- in a U.S.
YOU agreeto pay us amounts You owe in U.S. tiollan 1 aancial instit?tionUsing satpaymenl
financial institution or the U.S. branch of a loreig
check,moneY orderer automatic debittaseYour tolaldavallableacred tomayrnotcbe
institution. We will not accept cash payment.
restored for up to 15 days after we receivO your payment.
Any payment chock of other form of payment which you sued to that for less than the till
notation or that you otherwise tender
balance that is marked "paid in to"- or with a similar nlel, nmst be sent to us at the
i te
in full satisfaction of a dispute) amount lconditional pay t
conditional payments addresslisted oieV°lu it is°de'e? ninednhores We fuervo, nopvalid dilspute ohtit
regarding such payments. For examp vve may accept the payment and you
any such payment isreceived atanyother maddress,
ay refuse to accept any such payment by
will still owe any remaining balance, destroying it. All ohur payments that you make
returning it to you, not cashing
should be sent 1o the requfar payment address shown On YOU, monthly statcrne nts.
lt AP even 1here. is def Of it we do not
de not to aSV i
it we ncrease lVour APRtup fo tha In ximom dl gale statedain the IRates and fats defaul
We reserve the right to electronically collect your eligible payment checks, at first
presentment and any to presentment, from the bank account on which the check is Table we reserve our right to increase your APR in the event of any future ""statt_
We may in our discretion determine to charge reduced default rates or reinstate
drawn "lleck
t checks is your authorization
, DY send(ng the check standard rates for all or selected balances on Your account.
Method (Including New
drawn. Ourount ieceipt of your PaanenY if needed by
of the check electronically, or,
bank account. Payment checkswill6e collected etnumbers toby pf transactionsIfor example, purc
a hases,balance
we receive your payment. The aTransssoccaaspdctionsw)dh a We calculate periodic 1(nance charges seams(, p for each balance
the ammount along with the check, arty as the same day we roc eo?s bank Yourba bank Finance
category ersh ad vanco Bsa cash advance oil ks,o erdraft
account may be debited as early as th
transfers, balance transfer checks, ca
advances, and each promotion},These calculations may combine different categories
original payment check will be destroyed and an image will be maintained to ° adv the same daily Oenodic rates.This is how it works:
records. least the minimum payment due, as shown
Minimum Payment; You agree to pay at a meet is due. tim on your billing statement, so thalwe rec¢?ert`?Veh?nd n ay pay Ira Lull amount you We calculate Periodic {inanbe charges Sor purchases, balance transfers, di felt
a heschargesbecauselinancecharges for multiplying the daily balance for eaceCkaihosecategories eIhadaily Periodicrata V have owe us at any time. 11 you have a balance that is subject to Itnance charges, the transfer checks, cash advances, ca` It advance checks, and peer a Conte
you may pay more than the minimum pat
only nks).
each Of those categories, each day.nou 11 1 dra a 0 twith once offOurr related ba
cu pay us,the balance Y in clot you
ance and your ending balance (the have linked this account to e c
accrue o on your b baalance each day. WO calculatethe periodic finance charges for purchases, balance transfers, balance
Your billing statement shows your beginning Dal transfer checks, cash advances, and cash advance checks subjecttoapromotional
w Balance. on Your billing statement). 11 the New B alance is 510 .00 or l largest Of rate the same way but we use the promotional rat
otherwise, itwili be the
he New e.
,ance or each day or each ce.ry.
Ne
'No pay ant du2°k oill be f thelNew Balance;I Or the sum Of I%Of the NawBratanca,
limit ices. As To g We We at the daily Dal I
the lottowing: finance charges, and any billed late and over s, fees, ether charges, and debit
that balaneginningcbe a alany nce for new trthaatndsacay.tion
add e th to the beginning
total billed periodic rate advance,
i um m+ent due,we also add any amount pastdue and any amount W take
We add a new purchase, cash
Pa itotitleminm PaY adjustments that applytolhatcatagory.
over your credit line. alance transferor overdraft advance. it aPplicabb 'to the daily balance as of the 'ck advance Cite
Payment Allocation:!'atismoll lavorabl life oa tonvenienttotrruslFor your payments manic D
and credits in a way or balance transfer check to the daily balance as of the date the cash advance nsoction dale, or a let authorize us to apply Your payments and credits to balances with lower APRs(such check ore t an se rrchecke heck is deposited byaa payee, or abater date of out
bet bnsit,
as promotional APRs) before balances wilhhill r APRs. choice, Payments, cred
its, or credit adjustments that
Credit Balances:You mat request a refund of a credit ba lance at any time. We may • We subtract from that balance
ad n that are credited s, of that day.
reduce the amount Of any credit balance bytheamount 01newcharges orfeesD311ed apply tothat category;
to Your account. to automatically charge YOU' We treat a credit balance as a balance of zGro•for the next day, we add the daily
Automatic Charges: You may authorize a third party to get the beginning balance for each catng N note than one daily pel rala
account for repeat transactions (tor example, monthly utility charges, memberships finance a cazegorv
because your account is 10 becausel yabalance. it I category may vary based on the
our account P Triadic and insurance premiums). H automatic charges Y
are or any rea alectny re orason lincludspg could apply e daily balance, we will use the daily periodic rate that applies stopperifor the bitter and paying these charges amuun, of its averag Y at cycle to calculate the
closed or suspended for any ree
w° may, (or the average daily balance amount the end sf ohe billing tagreementyprovides for daily
number Chori you ore responsible (ornotil D mabut are Dot.required to, paY from
rectly, If your account number changes, daily periodic finance charge each day.
diyuvrnewaccounznumberchargestbatyauouthorizedtobebilledtoyouroldaccount compounding otlnancecharges
.
number to 7p get the total periodic finance charge for the billing cycle, we add all at the daily
Promotions: From tme time we may tiller special terms for your i 11 be L we
YOU about the terms of the oiler andhowlongthey wili be in effect, for each category for each day during that biting cycle.
eriettc finance charges
do, we willnotifyY as modified Uy the P Howev eriodic finance charge is duo, we will charge you at toast the
er, if any p.
minimumPeriodic finance charge staled inlite Rates and Feas Table. If iUS nucpssary
Any promotion is subject to the terms o1 this agreement,
promotional otter. m add an additional amount to Touch the minimum finance charge, we add that
FINANCE CHARGES amount,(, the balance for purchases made during the billing cycle.
rates are listed onthe Rates and roes The tom) finance charge on your account for a billing cycle wilt be the sum of the
daily Periodic Rates and Annual Percenltaag ge Rates: Your edo n t percentage rates heiodt finance charges plus any transaction lee finance charges. lrapsactions)
("APRs") and the corresponding daily periodic orate d To get the d aily
365, and inelfectalwayssounupatthefifth Fir eachcategvrywecalculateanaveragedailybalancelincludingn¢w
Table that is at the end of this document or provided s¢p' h• all our daily balances and dividing that amomn by
periodic rate we divide the APR by with changes for the billing cycle by adding y
place to the right of the decimal Point. the number of days in the billing cycle. If you multiply the average daily balance for
variable Rates: OneormoreAPRsthat applyloyouraccount rnayva stothePr(me the applicablodaily periodic tatUl peodic,theresullbythonumber
a categoryby tie, the total will equal the periodic finance charges for shat
totheprime Base. When Youhavean APR t margin totheSPrimeSato published inThe ptdaysinthebil cY ti or Minor variations due 10Toundiny.
Rate , we calculate the APR by balance atuibutable 10Iltat biting cycle, axcep
Wart Slreef i011/nallWO business day hS before est l? S11 PrClosing ime Ratte pubf sI rrd in tba Money Grace period and Accrual of FInance Charges: We acClue periodic finance charges
riodic
Ratessectionol7haWa115re.1f76.)rirretpubna7stupspubfishing pnalransaction,fee,orlinancechargefromthedataitisaddedtoyouratgoPaance
statement. The "Prime Rate"is thebig igh
unfit paymentin full it roc uveda ns billed co a b ll ng cycled wetrece ae magma 1 anyour the Prime Rale,weWill selectasimilarreferencerateandinformyouonyourbilling finance charges onnewp our minimum Payment c due and we
statement or through a separate notice. pt our New Balance by the date and time Y
A "margin is the percentage we add to the Prime Rata to calculate the APR. A
art we sduenThb; exce11 plion n?ugracle'penod appliesyonly
da that is not a we or federal holiday. The Rates and act, J Payment Yo ur New
business day" is any y it ant are variable rates. It also lists the margin for date and time your DaYm
Fees Table shows which tales, topurchases anddoes notapply tobalance lipad nDaisicetransferchecks,eesh rsfcrs. advances. cash advance checks Of overdraft advances, aa cash a 'Idvance
our billingstatement, we see you a co fee in
each variable rate and any minimum daily periodic rate and Corresponding A Transaction fees for Cash Advances: We may charge y
Two business days before the Closing Data shown marginto that Prime Rate fu gat
what the prime Rate is. We then add the applicable the amount stated in the Rates and Fees Table for cash advance checks and cash
the APR. The daily periodic rate is calculated as described above. advances. moot on your behalf and
If our calculation results in a change to a deity periodic rata from the previous bi mg payment to this account, we may charge a transaction Ieu
the new rate will apply as of the first In addition, it you use a third party service to make a pay
cycle because prime Rate has changed, a a hi her periodic the service charges the
Jay of your'i0ing cycle that ends in the calendar month in which we made the
add fee to thu ba
the Pr for the paymcM. cc finance Charges. We
,1031 Calculation. 101i I'll
daily perioic toaDaYna highees' r minimomipaln enlY y
related tf 3res gpry lees a the uansaci on dote ul tie calsh fadvancc Foraexamplc, a
finance charge and may in default under this agreement
Default Rules: Your APRs also may vasY if you are transaction lee for a cash advancewould he added to your cash advance ha ante,
or any other agreement you have with us or any of our related omPanles for any of Transaction Fees tot Bi , a g etas Taal charg° ayou n a balance ce checks tee
in the amount stated in the Rates and Fce Table for balance transfer checks an
the following reasons men) that is owed un this account or any oiler
We do not receive, for any pay balancetransiers.
These transaction fees are finance charges. We add the lee to the balance for the
account or loan with us, at least the minimum payment due by the data and tune as of the transaction data of the balance transfer. for example, a
due. related category You exceed your credit lino onth(s account. g transaction tee for a balance transfer would be added 11) your balance trans er
You make a payment to us that is not honored byyour bank. onal
balance.
any of make avant anYpthe caul
R D CHARGES
overdrah advances) up to a maximum of the detautl to OTHER FEES AN
yyppyyrr Opel'. tire W¢maychargeihefollowin9teel. Theamoumsofthesefeesarelistedint a acs
onallbalances leud'rng may c
olis
s and
Fee ,,to stzted in tbdefault rate: Tablalength of time your arccount has been papctors
¢?l2Fbusness and limingoitha defaults onyouraccountother indicalions and Fees Table. These lees wit! be added to the balance for purchases made During
as staled in the Hates and Fees Table),
APR) account usage and performance; information a'ou[yow ot; ain her from relationships consumer the .bil .I cycle. your account has an annual membership fee, it wi be The defil of whether notyouuseyoura l,andyputopayItwhenbitted.Theannual ccou your eu d info ation rate will take effect as of billed each year Olin monthly inslu installments (
wth us c any of our related comma Annual Membership Fee: If
des; ure and information we obt
credit reports obtained from creel I
the first day of the billing cycle in which he default occurs.
CMA12767
Page 2 of 5
Witting Arbitraiion.This Arbitration Anrooms DI is made pursuanIto a transaction involving
US that to
d be interstate commerte,andgUS'C.§1916asitmaybetam nded.ThisArbtra onAylfednent
membership tae is non-refundebts ounless urbiyounotify a tonwuwish e close Youraccount
a ouroutstandingbalanceinfull.yourpayment Arbitration Act. (the-FAA-1'
within 30 days of the date we mail your billing statement on hichllta annual membership lee is charged and at [hesametime,youp YY our sets!oRhthecircumstancesandproceduras under which claims (as delined belowl may
of the annual membership lee does not affect our rightto close your ac count or IimdV
make em ership a your account. If your account is closed by you or as, we be resolved re arbitration instead of bony litigated in court.
right fo our outstanding balance inclu artire s ourpadrenl `slobs die aoses s, aNiliate , l aensees pyredecesso s, successords, assiylns,
?Ccounl, and all of until you payY
ntinue to Cho rya the annual membership lee their tionsctiOns on
in full and terminate your account relationship. an purchaser of Yang allot them. Additionally. we,,'uss anal uutrsl air include will co include anlthr d
nd assigns or any
If we rm do not receive at least the required minimum payment by fi may le date
chaaterge Handie aA a providing Of benefits, services, or Products in cunnectron with the Account floc tiding
Late fee: t
me it is duo as shown on your biting statement for sole ice cycle, we ro rams and enroll that accept a c edit insurance companies.
late tee shown in the Rates and Fees Table. It the t rinyb tole fee is based on a balance, al party not 'Url calculate the late fee using the Previo s Barre as n New Balance shown on the prior The Account drewardspbugraus, merchants that accept any credit device issued Under
debtcollectors, and allof their oNrcers, directors, employees, agents and representatives
we e shows the late lee. This balance is Ills if, and onlyil, such a third party is named by you as a cu-defendant in any Claim gnu assert
montli s statement for which we did not receive at !east the required minimum Payment a ainst us. without the other's consent, elect mandatory,
by the date and time it was due.
Ovorlimit Fee: 11 your account balance is over your credit line anytime charge a hitting areay subsidiaries, other's s Co beneficiaries, agents or
we may charge an over limit fee. We may charge this feu Claims Covered. Either you or , dispute
cycle, even if only for a day, Y imposed binding arbitration of any claim, dispute or controversy by either you or us against the
other, or against rho employees, p
crag if your balance over the credit will not char of more than charge or teewa imp N meet.
or a transaction we authorized. We will not charge more one over
ubseque billing cycle. But we may charge verlountl if your account hittnce std` overt yif no our asYrPnsoofat of yher, arising from or retatiny in any way to the L'ardmember Agraemert
still is ofor ver any alt riorCardme uberAAgreement,your. re it card AccouA of ilia ntvc ver s all Claims, file
bala new transactions are made on your or app
credit line at any time during the subsequent brlhae cycles, whether such Claims are based on la or any loyal theory oi9awtsuch as reapondeat
N we `gust `arum common law, constitutional provision,
Return Payment Fee: If (e1 your payment check or returned instrument is not honored, tb injunctions, or declaratory Of equitable `offal. Clangs subject
a an pautoaymemnt atrc check debit beorcauotherelsflatc signed or cannot bpnedatcannotbe procesProcesd,seodr, w{)e may charge a superior, or any otherlegatorequdacedar tory¢uiaCi airelief kamsubjes an d se it is not money damages, paneltivs• licabilitY of this APo;tration
return payment lee. to this Arbitration Aereemenl include Claims regarding the app Agreement or the validity of the entire Cardmember Agreemem or any prior Cardmembei
we op relusu 10 on pay a a c caasshh adadvavancncee choccheckk or orbalbalaennccee transfer r Agreement. This Arbitration Agreement includes Claims that arose in the past, or arise
at you at your r rFee:equeIt tst, a) or ( b wel stop
chuck Return
check, we may charge a return check luu. in the present or the future. As used in this Arbitration Agreement, the term Claim is to
of a billing statement, sales draft or other be given the broadest possible meaning.
Admrdof your Fees: N you request a copy ClaimssubjectioarbrtralionncludeClaimsthataremadeascounterclaims,crassclaims, request !We 01 , o to ?ards at any special services
Third party claims, interpleaders or otherwise, and a party who initiates a procnoding in
serv record of obtaining carldsron anauxpedited bas s)mwe may ementsyou for these or sim lar
example court may elect arbitration with ruspac[ to any such palms advanced in the lawsuit by
However, we will not charge you lot copies of billing statements, sales drafts p sander ao party or parties.
docmnents that you request for a billing dispute you may assert against us under ovid e, the
taw, We may charge, for any services listed above and other services we provide, the As an exception to this Arbitration Agreement, you retain the right to pursue in a small ction
individu fees from time to time in effect when we oiler he service. claims court any lai that ti t ate i Ctaat court juralilon w Il b°dco due edas an individual party elects 11)
tion. . a Neither you not we agree to any arbitration on a class of representative bans,
-a , the DEFAULT/COLLECTION basis.
We may consider you to be In default it any of these occurs: and the arbitrator shallhava no authority to proceed on such basis. This means that even
it a class action lawsuit or other representative action, such as that in the form of a private
an o not receive a least the minimum amours due by the date and time due as shown ction l action, is filed, any Claim betwee a acts us related to the issues raised in such
on your billing statement.
• You exceed your credit fine, attorney general lawsuits will be subject to an individual arbitration claim if either you or we SO
without the
You [ail to comply with the terms of this agreement or any agreement with one of our No arbitration will be consolidated with any other arbitration proceeding
related companfes• consent of all parties. The only Claims that may be joined in an individual action under
We obtain Information that causes us to believe that you may he unwilling or unable to our Account or your hers Of your Misfile
in
pay your debts to us or to others on time, this Arbitration Agreement ora(l) those bruughl by us against you and any co-applicant.
joint cardmambcr, or authorized user at y
You file for bankruptcy. bankruptcy m 12) those brought by you and any co-applicant, joint cardmemGer, or
You become incapacitated or in the event, your y cfolsa Your account without notice authorized user of yourAeeounl, or your heirs or Your trustee in bankruptcy against us.
If we and (cunsder your account to diba inev inii ecialely. We alsomay require you to pay Jubilation of Arbitration. The parry filing a Claim in arbitration must chuose one of the
and require you to pay your unp' following two arbitration administrators: American Arbitration Association; or National
yntorust at the rate of turn portent (2 y) a month on the unpaid balance when we deem ArbitrationEorum.These administrators are independent train us. The administrator does
billing cycles past due. arbitration. Arbitration is conducted under the rules thestecteri
rules
our account 1o six or more and a
7o the extent permitted by lava, it you are in delaull because you have tailed to pay us, arbitration not conduct the administrator by an imparts) third party chosen in accordance with rilue ralon
may you will pay our collection costs, attorneys' tees, court costs, and alt other expenses of of the selected arbitration rbitration admini traat you attend she I bpro id at anpl ofaco choseniby
enforcing our rights under this agreement. Agreement. Any a
Ihe strator within the le of jach of distract a tic You
CLOSING YOUR ACCOUNT
if, You may class Your account at any t me. If You cat! us to close your account, we may ho arbitrator 0':' bitration administrator
rlisidazi tholint place of oli tyou he two
require that you confirm your request in writing.
We may close your account at any time Or suspend your credit privileges at any lime for wrrfne. You may obtarn rbit any reason without prior notice except as required by applicable law, If we close your administrators, information about he araifon and dministrat lees, and instructions or
American Arbitration Association, 335 Madison Avenue, floor 70
account, we will not t; liable to you for any tons equences resulting from closing your . Naw York, I4Y
initialing arbitration by contacting the arbitration admnistrators as Io ours: * be account or suspending your credit privileges. -778 If you or we close your account, you and any authorized users must immediately stop 10017 4605, Web site: wvvw.adr.ore, SOUK 50)S , or
using your account and destroy all cards, checks orothermeans to access your account National Arbitration Forum. P.O. Bbinau
or return them to us upon request. You will continue to be responsible or closed and s you your P ocedures and law applicable ic SOD 974 2371.
account, even it they are onl. AkSinyleap clutolOa bvalur v IL eso+lve
hare maade or proceseorprocesesed after after you' account is
arbitration is filed
ccordingtothetermso! Claims. The arbitrator will either be a lawyer with or least ran yearsexperiencaofa'euiud on your account be required to pay Dftho this a riding al in addition, to the extent allowed by laws amay require you to Pay he rules tthose pee ration admini rules are inconsistent at! in efie under the t ont has ate the procia.dwes and
d or former ARBITRATION AGRE ately or at any time slier your ccohntisclosed. MAY Unla-lcasetltis Codures and will les are These procedures and with this rules ration Acenl, it)
AGREEMENT I applicable suLstle am law
PLEASE LEAD THIS AGREEMENT CAREFULLY . I PROVIDES THAT ANY DISPUTE fs. The statutes of lilt apply ns, and will honor ctive l of
BE RESOLVED BY BINDING ARBITRATION. BU ARBi TRATION REPLACEST RIGHTTO 60 of discovery available to you or usable s oslei hovel it a earny and be represented by
ATTORNEY COURT. YOU WILL NOT DE E ABLE TO BRING R CLASS ACTION OR OTHER ER consistent with the FAA and app
REPRESENTATIVE ACTION IN COURT SUCH AS THAT IN THE FORM A PRIVATE oo recognized at law. You may
ATTORNEY Y GENERAL L ACTION, NOR WILL YOU BE ABLE TO BRING ANY CLAIM IN counsuunsc).Theo`bitrafarwilltake reasonable stepstoprotectcustomerAccountinlormauan
ENTATIVE ARBITRATION AS A C ACTT ASS HE ACTION DR OTHER REPRESENTATIVE ACTION, YOU WILL and other confidential information, bncitidiny tire use of prowchve orders to prohibit
BLETD B£ PART F ANY CLASS ACTION OR OTHER REPRESENTATIVE ACTION disclosure outsidle e the arbilrali on, rf requested to do so Gy you ur us. The arbitramr will
power award rto a a party any damayes or other `offer provided for under
BROUGH
BROUGHT BY ANYONE ELSE, DA BE REPRESENTED A IN A I T CLASS ACTION Ofl A OTHER
IMS have the applicable law, and will not have the power to award relief to, against, or lot the be relic ABSENCE OF THIS REPRESENTATIVE HAVE HAD A A RIGHT LIGHT OR OR OPPORTUNITY NITY
'AND ND W WE MAY OTHERWISE RTUUNITY TO O BRING BRING CLAIMS of any parson who is not a party to rho proceeding. If the law authorizes such relief, the
fN M?FQRIEAt JUDGE ORJURY, ANO/ORTOPARTICIPATE 01 R BE REPRESENTED arbNra?al=g"varoup1mor us, iti the mage? orwtor provide as. The! arbitrator will make any brief IN? * ACTIONS). Y OTHEnS (INCLUDING CLASS ACTIONS 14D OTHER Uponatiregoesgbyy aednotprovideastatementolreasons unless requesied by a party YOU HAVE IF YOU WE14T .
TO REPRESENTATIVE A
COURT, SUCH AS DISCOVERY 09 THE RIGHT TO APPEAL THE DECISION MAY , For the award.
M roof of tiaYmeot. Additionally, a there is a Danny, we
ORCOUELtMITEO.EXLEPTASOTHERWIS ISEPROVIDEDBELDW,THOSERiGHTS ARE AREWAIVED amour of S50Drupon receipt pt of far the `gloat ant. ddi !fling lee paid by you up u i he
Page 3 of 6
CMA12762
TELEPHONE MUNITOR114G AND RECORDING
us will be made directly , anditapplicabieoutagents, may listen to and record your telephone cans with
to an albilf3firin acirrinlistf3tior r ylsuch hearing fees by Us (o Will the first two day, is may lislon to anti record your telephone cols Willi
if applicable, our agents, may do so, whether you or we
will pay ahy lees of the arbell` ofa
a administrator select¢d by you or us pursuant to this Arbitration us. You agree t as we, nd
to the rbitration tration initiate the telephone call.
of that hearing. The payn in with the rtrlosof the arbi
greemart All Other leeswelaw However. we will no e appl iabie law. However, w will advance or reimburse tiling fees tou B o Aolmpanies and witb others outside our fam
and other fees it the a Ic lion od re sask tf l us a r wetratorrmener t thrift) is good souse You authorize us to share certain informr m nac ay appear on on the 1 Est ireceiveo IltifiI YOU and your accoun within ur ark A an
administratorand ile ca rrds? as permuted
reason tgrrequiring US to do so Yo any or orgamizationwhow which is l vided 1a 0 you
will bear the aexpense of She leas and costs 0111 at Party s bylaw ur Privacy policy, which is pr
have and direct eunseyoubmay ugr inlormatrun
for doing so. Each party ive us about
eel {as pernti l ad below), except that the agreemantand at leastonce each calendar
attorneys, experts. witnesses, documents nd other expenses, btflo er a Ipany of
Should t utd sharing practices and the choices y
party prevails, for arbitration and any app our sharing of information about you and your account with companies or
arbitrator shali 3PP1V any applicable law in determining
fb'l c r any o finality, appeals. Failure or any delay in enforcing this Arbitration organizations within and outside of our family of companies.
recover any or all leas and costs from another party. ILLINOIS CARDMEMSERS
Enioemeril. greement at any time, Orin Connection with anypaaterti ar orindin 191111 n with any Claitnonne tion With any Illinois, law p d
A
a waiver of any g roceeding will be final and or other organizations outsids authorize the
ri ills to require arbitration at a la p disclosure or unless vtthae disc e loureo our falisa family under of oa companothur nies exceptunlesson n you i the law (such
other Claims. Any decision rendartan such he aiaatwrarbitratio" as sharing
ling on the r Claims. par decision rr n party appeals eel must request information to process your transactions or in response to a subpo¢ua .
bill( ithin?0Jays ofissuenee of the award. The app You hereby agree that, if you choose motto exercise, he oliz-e able opt out describe)
Othe
in our Privacy Policy, you will be deamedtnevhmat on (start d to any of the products
before a panel of three neutral arbitrators designated by the same arbitration
w
ill of other
organization.The panelwreconsider all iactualandlegalissuesanew,lollowt a n servo yeu may h hav ave with anny y of our companies) with companies
i to a proceeding using a sin gle arbitrator, and make decisions information we have about you (including y
family of comp
same rules that app y Each patty will bear their own fees, costs and antes.
basV d On the vote of the mayority ac any or all fees, costs and expenses organizations outside of our
expenses for any appeai•,bul a party V rarty " appIYing , ed a Usable
revrd¢dbyth¢ ENFORGING7HISAGREEMEN
eniorcin grog!enforceanyofov?rrightsundcrthisnyr¢ernenpwn out
from another pn ty, if the malonry of the pane! of arbitrators, We can delay g
law, so determine . n ward any oourt haw ngjur'nsdiction.ble asp losing our right to enforce ahem in the future. If any of the terms of this agreement
FAA or other app are found to be unenforceable, ail olhertenns will remain in lull force.
SevetoWill. survival. This Arbitration Agreement shall survive: W termination or ASSIGNMENT
We may assign your accmrnt, any amounts yon nwu us, or any of our rights make a tnhe
chanes in the Cardm¢mber Agreement. the Account and the relationship between
g
you and us concerning the Account, such as Itw issuing p} a ou new aor onccouyont ur beh numbaet li; obligations under this agreement t^ a third party. Thu person to whom we
s milai proseiingUnniaoeJ by Y another account; be the assignment will be entitled m any of our rights that we assign to that person.
the transferring art tort balaqe in the Accont.
obr ankruptcy of a0Y p Y if any portion of this
and {iii) payment of the rlebr in lull by you or rY a third party. onions GOVERNING UtW
Ar11100iameeOftile deemed invalid or unenforceable, the it, ningp THETERMSANDENFORCEMENTDFTHiSAGREEMENTANDYDURACCOUNTSHAI
REGARD
Arbil nevertheless remain in force. BE GOVERNED AND INTER PRETED IN ACCORDANCE WITH FEDWITHO T AND, TD
EEMENT THE CYTENT STATE LAVY PRlNClPLES77HE LAWOOFF DELAWARE, WHET
CHANGESTDTHIS AGR WE AND cces
LAW We can change this agreement at any time, regardless of rev sionf Ourlright to add, yDURAGCDUN7ARE LOCATED, WILLAPPLY NO MATTER WHERE YOU t.lVE DR USE
diymg an
to your account, by adding, deleting, or mo APRs and fees, THE ACCOUNT.
delete, ur modify Provisions includes financial terms, such as the the ights and
FOA INFORMATION
and other terms such ahlrettrs agreement.Modificationsraddilion , Please calithe Cardmember Service lue number oil your card ' billing
obiigaliousyou or we mayy ave latig to may statement it you lrove any questions aboutt Y yourour account or this agreementt.
or deletions are called Changes' or a "Change (cable law. These Changes
We will notify you of any Change it required by app ifeepThis Notice For Furore Use
ant information aboutyour rights and gut responsibilities
be eilective with notice only, al the time stale d in our Police, in acc toordatience w^th unpoid Th s R oticolNonidlins import
applicabie law. Unless we state otherwise, any Change will apply
balances on Your account and to new Transactions.
Notiiy Us In case Of Errors.0f ou VDU r Abou ere n ration about a transaction ct to Th notice gwil s c qou da orndotno?axerclsealhoser dghlsPFor exa pier he not ce underline Fair Credit Ril mg c . Your B lm
1, any may state that you may notify us in writing by a specified date H you da not want to o you Think Your hill is wrong,
accept certain Changes we are making. li gnu nobly us nt writing that you do nut on yoUrbill, writeus on a separate sheet at the Cart ossi her Service address sown
on your billing statement. Writs to us as soon as possible. We must hear Iron you
bill or) which the error yr problem
our outstanding balance under the applicable terms of the no 131er than 60 days alter we sent you the first hts
accept the Changes; yoyuyr groats[ maybe closed (u it is not already closed) end you no ppeared. th You can telephone us, but doing so will not preserve your rig
wilt be u ligatad to pa the date stated in the notice,Or" You be
t. fl you Jo not nutac us in writing by will
agreemen .
In your
nosily us but then use fetter, give us the following information:
your account after the data staled in the noose, Y ollar amount of ire suspected error.
notice and to accept and confirm all terms of your name and account number.
deemed to accept all Changes in the we have sent you regardless of The d
your agreement and all Changan in priot noai Describe the error and explain, if you can,wl you believethere is en error. I1 you
whether you have access to Your account. need more information, describe file item you are nut sure about.
GRE017 INFDRMATION d us to pay your creditcard bill aulornatically item your savings
We may periodicaliy review your credit history by obtaining information from credit IfTor checki')g accuutil, Yo 'On slop the oyou stop havthe e ap Yrnuthorizeenl Youa latter roust raaeh+us}alvluast ihreLUbusinessrJays before
bureaus and others. moot is scheduled to occur. en
Wemayreportiniormalionaboutyouand including
the automatic pay
your failure to pay us on time. II you request additional cards on your accountnt for for
others, we may report account information qtr in auditname a wail as in the names of Your Rights And Our Responsibilities Alter We Receive Your Writt Notice
We nmstacnknowed 90 daysl tt must in 30 days, u lesserrorha c lain whytwne eilhvr those other people. may error by f
11 you think we have repurled inaccurate information to o credit bureau, you en believe the bill Was CDrra6l. ueshon, or
hone "umber and a brief parr we receive your Inner, we cannot try to collect any amount you q
write w us at the Cardm¢mher Service address listed on your billing stateme . r c v aiyouent. We can continue to bill you }or the amount you question,
Please include your name, address, ous"""t a pr v iletup o} the credit bureau sporty. Ian un aid amount uyainst your credit
description o1 the Problem. if avaihbnvestigall thematter and, if Dur investiymion including finance charges, and ,,a can app Y Y P'
report in question. We will promptl y `I line. You do not hav¢ to paY any questioned amount while we are investigating, but
a shit obligated pay the parts of Yuur bill that are not in question.
shows that you are right, eve wdf contact each credit bureau to which so repo notify rte th r!e you f wo re S :hat wo made a mistake on your bill, you will not have to pay any finance
willalso me
outher investiginformationaation, nd we a will wrill jail yo¢ell you in f) corr ec writing tt or he by report.11 t°I¢Phonewe. dis We agreewithyou alter to uostioned amount If we didn't make a mistake, you may
nu on
ited t a charges, and you will have to make up any misscit paY
know hat You "" hove to p. Y
credit bureau that you dispute the information unless you fat us charerges related to any q
longer dispute the information. the questioned amount in either case, we "M send you a statement of the amount
NOTICESICHANGE OF PERSONAL INFORMATION you owe and the date that it is due.
statcmartsandnotices it youiailtopaytheamount that wethinkyouowe.wemayreportyouasdelingvent.
We will send cards, billing statements and other notices li you at the address sbow^ yowever, it our explanation dues not satisfyYou and you write to us within 10 days
in our files. Or, if this is a Joint acoount, wo can send billng a our name, we roust tali anyone we report you to trot you
to any joint account holder. Notice to one of Y°° will be considered notice to all of telling us that you still refuse to pay,
you and all of you will remain obligated on the account. 11 You Chang Y have a question aboulyune ilill.A fd• a inustilefly a mattearhas be¢n senewu ttled between
g ou must notify us you [o. Wemustte11anyo
address, or homeb lli gisiatements or rohert notices online), gent address r you
E?01 us when ft itili
these rules, wa can't collect the (first 550.00 01 the quesuoner
)writing at the address shown on your billin statement. We may, at
lion,acceptmarling5ddresscorreclionslromtheUnitedStatesPostalService. tf we don'ttoliII ow t
our op emounL evemii your bill was correct.
Wu maycontaetyouabontyouraccount,inciudingforcustomer5erviceorcolleetion, oons,Rven,,, rurbiilCardPurchases
ll as any cellular telephone number you
at any address ortefephone number as we Sp
provide us.
CKAA12762
Page 4 of 6
It you have a problem with the quality of property or services that you purchased with a
credit card, and you have tried in good faith to correct the problem with the merchant, not
iii m
due
amou
the
check t ansactiovns. The enarre two limitations on th sBright:s
on the Thi mghttdoes notvapply to
(a) you must have made the purchase in your home state or, it notwithin your home state,
voithin too miles of your current mailing address; and
(b) The purchase price must have been more than S50.00.
These limitations do not apply if we own or operate the merchant, or if we mailed you the
advertisement for the property or services.
Copyright 02007 JPMorgan Chase & Co. All rights reserved
8362161
CMA12762
Page 5 of 0
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904
relating to unsworn falsifications to authorities, that he is _..__N 1 Aj Alcaraz
Assistant Treasurer of Chase Bankcard Services Ir?c. , a subsidiary of the
(Title) (Company
plaintiff herein, that maintains the records for and services the credit cards accounts owned fac by plaintiff and he is duly authorized to make this Verification to and the best os that Chef his kset
the foregoing Complaint in Civil Action are true and correct
information and belief.
(Signature)
8352161
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ~1~.ED-~ ~!~
f k-+ ; ! f1i
Sheriff
,,, ,
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
~'.4 ~.,, V ~v
PEI~1~~iSYLV~i~IA
Chase Bank USA, N.A.
vs.
Kelly A. Rugh
Case Number
2010-5521
SHERIFF'S RETURN OF SERVICE
09/09/2010 05:25 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September
9, 2010 at 1725 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kelly A. Rugh, by making known unto herself personally, at 1218 Pine Road, Carlisle,
Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the
said true and correct copy of the same.
SHERIFF COST: $33.40
September 10, 2010
~''~--~
DENN FRY,D
SO ANSWERS,
RON R ANDERSON, SHERIFF
-_?n-
f i t r s ;„
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
vs
KELLY A RUGH
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
08352161 C J Pit SJS
Judgment Amount $18357.66
An
Q
b?p
Plaintiff No: 10-5521 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMF,NT'T
Defendant FILED ON BEHALF OF
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS. Civil Action No. 7-0-5521 CIVIL TERM
KELLY A RUGH
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant KELLY A RUGH above :lamed, in
the default of an Answer, in the amount of $18357.56 computed as follows:
Amount claimed in Complaint $1'7842.77
Less payments / adjustments made $0.00
Interest on the remaining principal balance of
$17657.01 from August 06, 2010 to October 19, 2010
@ the interest rate of 6.000. per annum $214.79
Attorney's fees $300.00
TOTAL $18357.56
I hereby certify that appropriate Notices of Default, as attached have
been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the
Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: _ < .. 11-
James C. armbrt,42524
08352161! CIJ Pit SJS
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400 Pittsburg VPA 15219
And that the last known address of the Defendant is
KELLY A RUGH
1218 PINE RD
CARLISLE, PA 17015
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HANK USA, N.A.
Plaintiff
VS.
KELLY A RUGH
Defendant
TO:
KELLY A RUGH
1218 PINE RD
CARLISLE, PA 17015
Date of Notice: - 10jq11D
Case No. 10-5521 CIVIL TERM
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. 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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717) 249-3166
WELTMAN, WEIN
G & REIS CO., L.P.A.
BEEL
By:
Matthew Urban
P.A.I.D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
8352161 J PIT B4S
IN THE COMMON PLEAS COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS.
KELLY A RUGH
Defendant
Civil Action No. 10-5521 CIVIL TERM
NON-MILITARY AFFIDAVIT
The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within
matter and states as follows:
Affiant states that the within Affidavit is made pursuant to and in accordance with the
Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521.
Affiant further states that based upon investigation it is the affiant's belief that the
Defendant, KELLY A RUGH is not in the military service.
Affiant further states that this belief is supported by the attached certificate from the
Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any
information indicating that the below individual is in the military service:
KELLY A RUGH
1218 PINE ROAD
CARLISLE, PA 17015
Affiant further states that the averments contained herein are true and correct to the best
of Affiant's knowledge, information and belief and that these averments are made subject to the
penalties of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities.
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Oct-29-2010 07:52:11
< Last First/Middle Begin Date Active Duty Status Active Duty End Date Service
A
enc
Name g
y
Based on the information you have furnished, the DMDC does not possess
RUGH KELLY A any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL ho://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 10/29/2010
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCR,4 is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:25MKGCKO00
https://www.dmdc.osd.mil/appj/scra/popreport.do 10/29/2010
.
CHASE BANK USA, N.A.
Plaintiff
vs.
KELLY A RUGH
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Civil Action No. 10-5521 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following Order of Judament
was entered against you on --
(xx) Assumpsit Judgment in the amount of $18357.56 plus costs.
( ) Trespass Judgment in the amount of $ plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle
operator's license and/or registration will be suspended
by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration Award
Prothonotary
By' 17--?ez-
PROTHONOTARY ( DEP TY)
KELLY A RUGH
1218 PINE RD
CARLISLE, PA 17015
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION
HSBC BANK NEVADA, N.A.
Plaintiff
VS. Civil Action No. 10-5521 CIVIL TERM
KELLY A RUGH
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the
following Order or Judgment was
entered against you on
(xx) Assumpsit Judgment in the amount
of $18357.56 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
DENISE ROGERS
GREENSHIELD FINANCIAL SERVICES
1301 Central Expressway South, Suite 200
Allen, Texas 75013
By:
PROTH ARY (OR EPUTY)
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 71 Avenue, Pittsburgh, PA 15219
1-888-434-0085
WELTMAN, WEINBERG & REIS,CO., L.P.A.
BY: William T. Molczan,47437
I.D. No. 47437
436 7th Ave Ste 2500
Pittsburgh PA 15219-1842
(412) 434-7955
FAX: 412-434-7959
File # 08352161 C J Pit SJS
Attorney for Plaintiff(s)
CHASE BANK USA, N.A.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
vs.
KELLY A_RUGH
CASE NO. 10-5521 CIVIL TERM
PRAECIPE TO SATISFY
TO THE PROTHONOTARY:
Kindly mark the case and judgment entered against Defendant KELLY
A RUGH as satisfied.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By 14 . Molc an
Attorney for Pi'aintiff
ctod :60,01
Ck_H ll8`y87d9