HomeMy WebLinkAbout10-6462SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
~KSp pf '~Irtribt~/
Jody S Smith ,i~~
~~
Chief Deputy ~-
Richard W Stewart
Solicitor ~,CE >>~ T~-: ~<~R~~~~
Chase Bank USA, N.A. Case Number
vs.
Shirley Arnold 2010-6462
SHERIFF'S RETURN OF SERVICE
10/20/2010 09:55 AM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on
October 20, 2010 at 0955 hours, he served a true copy of the within Complaint an otice, upon the withir
named defendant, to wit: Shirley Arnold, by making known unto herself p rsonall , a 1142 Pheasant Drive
North, Carlisle, Cumberland County, Pennsylvania 17013 its contents ar d~a~he a e time handing to hei
personally the said true and correct copy of the same. (' ~ /
S
SHERIFF COST: $33.40
October 21, 2010
~' ,>~ ad z~ i~o a~~~
,~,~`~tt~~~GN? ~~ ~~..~1.
~~t~.~t~-Q3~}!
,DEPUTY
SO ANSWERS,
~~
RON R ANDERSON, SHERIFF
rrj Coon+ySuite Sh~ntt. Tei~bsoft. Ir:;.
s
OF THE PRprHONOTAR`
2010 NOY 29 PH 3: 07
PuMBERLA
PENNSY
COUNTY
turn
CHASE BANK USA, N.A.
Plaintiff
V.
SHIRLEY ARNOLD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010 - 6462 CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE FOR ENTRY OF APPEARANCE
To the Prothonotary:
Please enter my appearance on behalf of the defendant, SHIRLEY ARNOLD, in the
above captioned case.
By:
Respectfully submitted,
IRWIN
, P.C.
Marc g t, III, Esquire
60 a omfret Street
Car isle, Pennsylvania 17013
(717) 249-2353
Attorney for defendant
Date: November 29, 2010
CHASE BANK USA, N.A. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010 - 6462 CIVIL TERM
SHIRLEY ARNOLD,
Defendant CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was
served upon the following by depositing a true and correct copy of the same in the United States
mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and
addressed as follows:
Matthew Urban, Esq.
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
IRWIN & McKNIGHT, P.C.
By: Marcus/A. McKnight, III, Esquire
60 Wes Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: November 29, 2010
2
CHASE BANK USA, N.A. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010 - 6462 CIVIL TERM
SHIRLEY ARNOLD, ,. *
Defendant CIVIL ACTION - LAW rnM
«crn o ??*?
NOTICE TO PLEAD ti
• C co q r-)
-''?
TO: CHASE BANK USA, N.A., and its attorney, c?
Matthew Urban, Esq.
co
:Z)
-<
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE
ENCLOSED ANSWER TO COMPLAINT WITH NEW MATTER WITHIN TWENTY (20)
DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU.
IRWIN & McKNIGHT, P.C.
By:
Date: November 29, 2010
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court ID. No. 25476
Attorney for Defendant
CHASE BANK USA, N.A. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010 - 6462 CIVIL TERM
SHIRLEY ARNOLD,
Defendant CIVIL ACTION - LAW
ANSWER TO COMPLAINT
WITH NEW MATTER
AND NOW comes the Defendant, SHIRLEY ARNOLD, now by marriage SHIRLEY
VALENTINE, by and through her attorneys, Irwin & McKnight, P.C., and makes the following
Answer With New Matter against the Plaintiff, CHASE BANK USA, N.A., as follows:
1.
The averments of fact contained in Paragraph One (1) of the Complaint are admitted.
2.
The averments of fact contained in Paragraph Two (2) of the Complaint are specifically
denied. On the contrary, the Defendant is known as Shirley Valentine.
3.
The averments of fact contained in Paragraph Three (3) of the Complaint are admitted.
4
The averments of fact contained in Paragraph Four (4) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
2
5.
The averments of fact contained in Paragraph Five (5) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
6.
The averments of fact contained in Paragraph Six (6) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
7.
The averments of fact contained in Paragraph Seven (7) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
WHEREFORE, Defendant, Shirley (Arnold) Valentine, requests that this Honorable
Court dismiss the Complaint of the Plaintiff.
NEW MATTER
8.
The averments of fact contained in the Answers of the Defendant are hereby incorporated
by reference and made a part of this New Matter.
9.
The name of the Defendant by marriage is Shirley A. Valentine and not Shirley A.
Arnold.
3
10.
The Complaint of the Plaintiff should be dismissed or amended to name the proper name
of the Defendant.
WHEREFORE, Defendant, Shirley (Arnold) Valentine, requests that this Honorable
Court dismiss the Complaint of the Plaintiff.
Respectfully submitted,
IRWIN & McI?FIGHT,
By:
Marcus A. 4c ,
Supreme Co D.#25476
60 West Po fret Street
Carlisle, PA 7013
(717) 249-235
Attorney for the Defendant
Date: November 29, 2010
4
VERIFICATION
The foregoing document is based upon information, which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904 relating to unsworn falsification to authorities.
0- K
SH EY A. VALENTINE
Date: NOVEMBER 29 , 2010
CHASE BANK USA, N.A. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010 - 6462 CIVIL TERM
SHIRLEY ARNOLD,
Defendant CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was
served upon the following by depositing a true and correct copy of the same in the United States
mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and
addressed as follows:
Matthew Urban, Esq.
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
IRWIN & McKNIGHT, P
By: Marcus A?M ight4zj,?e
60 West P m et Street
Carlisle, PA 1 013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: November 29, 2010
5
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, NA,
Plaintiff,
VS.
SHIRLEY ARNOLD,
Defendant.
Case No.: 10-6462
MOTION FOR SUMMARY JUDGMENT
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA ID# 90963
Weltman,Weinberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
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W WR# 8467943
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, NA,
Plaintiff, Case No.: 10-6462
vs. MOTION FOR SUMMARY JUDGMENT
SHIRLEY ARNOLD,
Defendant.
MOTION FOR SUMMARY JUDGMENT
AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co.,
L.P.A., and hereby files this Motion for Summary Judgment against the Defendant. In support thereof,
Plaintiff avers as follows:
1. Plaintiff filed a Complaint against Defendant seeking judgment in the amount of
$9,892.70 with interest at the interest rate of 6.00% per annum from September 28, 2010, plus attorneys'
fees of $300.00, and costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A"
and made a part hereof.
2. Attached to the Complaint was Verification from an authorized representative of Plaintiff
verifying the accuracy of the amount sought. See Exhibit "A".
3. Defendant filed an Answer to Plaintiffs Complaint. A true and correct copy of the
Answer is attached hereto as Exhibit "B" and made a part hereof.
4. On or around February 24, 2011, Plaintiff served upon Defendant a set of requests for
admissions and requests for production of documents. A true and correct copy of the same is attached
hereto as Exhibit "C" and made a part hereof.
5. No response to the discovery demands has been received from the Defendant.
6. The requests for admissions are now deemed admitted under Pennsylvania Rule of Civil
Procedure 4014(b). Thus Defendant has admitted that she applied for, received and made use of the
WWR# 8467943
credit card; that the statements attached to Plaintiffs Discovery Request correctly identify the payments
and/or credits, purchases and/or balance transfers and/or cash advances, and interest rates; that she has not
submitted any written disputes as to billing inaccuracies; that the account accrued interest at a variable
rate; that she has made no payment on the credit card since November 01, 2009; and that $9,892.70 is a
correct and accurate balance on the credit card account.
7. By way of her Answer, the documents attached to this Motion, and the Requests for
Admissions, deemed admitted under Pa.R.C.P. 4014(b), the Defendant has admitted all facts material to
this matter and verified the amount owed.
8. There are no meritorious defenses against this action and Plaintiff is entitled to summary
judgment as a matter of Law against defendant.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant summary judgment
in favor of Plaintiff and against Defendant for $9,892.70 with interest at the legal interest rate of 6.00%
per annum from September 28, 2010, plus attorneys' fees of $300.00, and costs.
Respectfully Submitted:
By:
Matthew D. Urban, Esquire
PA ID# 90963
Weltman,Weinberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
WWR# 8467943
p.j
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ZQ10Cr' 1L 3' ?8
.r
CUMBEp;
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A_
Pla.inti ff_
VS.
SHIRLEY ARNOLD
Defendant
No:? -??
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warm.jr_odt, 42524
WELTM=- llj, WEINBERG cr REIS CO_ , L . P _ A .
436 Setrenth A-venue, Suite 1400
Pittsburgh, PA 151''19
(412; 434-7955
FAX: 412-338-7130
08467943 C A Pit FT,r,, "
li-AAl
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N_A.
Plaintiff
SHIRLEY ARNOLD
Defendant
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
NAVE 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 -\T A REDUCED FEE OR NO FEE_
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIA"ION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff, CHASE BANK USA, N.A. is a corporation with offices at
200 WHITE CLAY CENTER DR NEWARK , DE 19711 .
?. ?°LeP_daP_t ij adult 1nd1'v`idllal I ) residing at he i1Cress liSt ?
below:
SHIRLEY ARNOLD
1142 PHEASANT DR N
CARLISLE, PA 17013
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXX1215
4. Defendant made use of said credit card and has a current balance
due of $9892.70
5. Defendant is in default of `he terms of the Cardholder Tlareement
having not made monthly payments to Plaintiff. thereby render--ng the
entire balance immediately due and payable.
6. Plaintiff: avers that the Cardholder Agreement betwee-i the parties
provides the Defendant will pay Plair_ti.f` 's attorneys' (-es
7. Plai ntif avt_,rs that such attorneys' fees will amot ni, 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.
here-ore ?e Plaintiff prays for ,'1d T?ernt aaai nst T:eierdant
SHIRLEY AP.NOLD , individually , the amount of $9892.70 with continuing
interest thereon at the statutory rate of 6.000< per annum zrom
September 28, 2010 , plus attorneys fees of $300.00 and costs.
James
WEL ,
436 S a
08467943 C A Pit KMJ Pitts urJ
(412} 43r
FAX 4
This law firm is a debt collector attem ng
our client and any information obtained will
'Wa ro t,42524
OWh EINBERG & REIS CO., L.P.A.
Avenue, Suite 1400
3h, PA 15219
1-7955
-338-7130
to collect this debt for
be used for that purpose-
Paym4rt Due Dame Now Balanv Past WeAmount Mlrimum Payment
00./0Rrf0 $0,692.ro 12,073.00 i].4gS00
Account lambert 41t15 3000 0210 121'3
Ch C
w rb armn2 and01M.
s F_-? gym:
Now elldrm o2 em.M Print ort be4k.
'!3?SSu6Q02bf312b5QQ24Q5D?JQG99`?2?*?QOQQQQQQDOQQQQ3
HIRL
LEY MNOL OLD
SHfR
1 t42 PHEASANT DR N CAROMEMBER SERVICE
CARLISLE PA 17013-1261 PO BOX 16163
WILMINGTON DE 1a6E6-5153
1:50001,60281: 499600210112151,00
CHASE O B yYaaGa y.ur e. runt a i{ w: Addle ..d -*.4 .4 W nna9en
1177EICaa1] c9meriuildyk9amd an rwaeo lido
ACCOUNTSUMMARY
Account th ntber 4186 5060 0210 1 216
P"ous Boanm 59.66020
Foss Crwood 4530,00
InteretC Charged 4SI94.41
New 3.!-m 50,602.70
Opur m-Ci-dng Date 04113"0 - 05$12110
Total Qedit Uno 56.500
Available C,edlf $0
Casa Acoees tine $1.700
AvaiYNo for Caen so
PAYMENT INFORMATION
New Bdanae E9,1y02.ro
Payment one Cafe COMM
hfNrrum Peymem Due $2,405.00
Lola Payment Waning: It we do not mcnive your mnimm
payrtuem by the deb fated alms. you nay here to pay up to a
$39.00 tare Us and Your APRs vM be wtiso to iwssaa 10 a
"ventral" Paally APR of 29.06%
w Imam Pays em Warning. it you melee 0" ate rirlmum
payrvm "Ch period. YOU w9 pry more in ktereel and h Wd I"
yo:tton9ertopayaHyourbdmv. Forexanow.
e ym makem You w0 psyo8lhe And you will end up
ed49ond char" befenca dtow0 w paying al091hu rod
wing tnh raid aM INS etawasnl In total of...
"M monm you abort..
P0y-..
OdygreniNnesn 34 y?sra 529.506
pay-t
17Pt 3yeara $14.062
(S5%bVb-S16.444)
i you vrn"J. aiw ?montic-rt about cmdtcmmdit aenfcm, colt
1.966-7+>.Y7%.
The ouutandkig telanv an ycur wade card a?r_m .n +chodulod io be -,an oti w abed debt etonly. Aa arestli, yow erel5f
bweau trill be Wdatad with a negative rating that x io feet tw up to sew-. yame. we can sit hela but you need to cal sm non m
I-am-792-7547(mlect 1-302-504-92061.
hapWanl Mssespe' You Are 0vad4mh2
Your staler-1 balance "a eds year ere6t ins. -- ah9:id mnu, „ • wYI-4 that i dvdas ha ma.lma --1 to b*V the
balance under yoga -d4 Ilea.
ACCOUNT ACTiy T Y
Data of
7rwaacion Mon nam Nllmeor ?.---u n Dex:+p-n +?1t SAn1wm
. \wm - `:^.:aY>t\.., ?..r76QU`.?5 . ?,ti
Nn 5 06/09 ?n - FEE ao :.?1
_ TOTAL FEES FOR THIS PE9'OD
05112 = r- a:£ INTEREUr C,HAEIOE - 6
Ofi/12 _ ;- r ' E INTEREST CHARGE ;FG °_i
TOTAL (NiEAEST FOR THIS PERIOD $194.41
Total rase [ha;,ad lrt 2010 Ste5.00 .
Tatelkaema&M in Mtc 5150.44
YeW4040' toeea ea dtariiftnima-, -?ea
eppiad to ;ow amount w 0. after 3rnuaty I .
INTEREST CHARGES
'+eur annual Per"m.ge R- (APR) 1. Ulm snnuad jn,-q j rel. ,- ; ?w aemur!
Annual 3.tanoe Accroed
8a4c? P cwVIxq. R. 10 JAPR) Subf.ct To In.se:<t Interact
8467543 7"- 30 Day. In Cyble Ime..tl Rey. Ch.rpee Ct1.,ge0
Purcllesea 24.24%(") Sa,iS2A3 $79 1a co
Pwdlase6 2424%(N £6.20 >. _ $0.00
ThIS Statement IS a Facsfmne - Not art arigtrla)
W00901 FPi1lye Ot+_ we N 2 12 :9"06111 P-1 d3 2aee wMA 1.110
x .o cao9I .,cmealner.
EXHIBIT
I
2 Of S
Stslenw t Oate: 0413110 - 05/12/10
Accourn Numbs; 4106 5060 0210 1216
Pap6 2 of 2
INTEREST CHARGES CONTINUED
Your Annual Paseef"290 Rata (APFgfa Via arnual Irnaras rate m your a=unt.
Annul Balance Acvual
aalonce ?ereentaga Aefe(APR) Subloct To fa east t t.1.0
.Type 304eys!n Cycla Interest R.I. Chargee Ch-g-
-ash Aavencee 2A.24Y.M Moo 90.00 50.00
Caat A^vencee 24.24T'a M $000 90.00 50.o0
(vj a Varletla Rns
please see IMomletfon About Your Acoou f saofm for the Calmlalton of Balance "so to Inleraw Rare. Airnral Rer e-al Nmloa
How to Awed Merest w PurCna n. and over irrponarit ireommtion, as ap'p'cable.
8467943
This Statement is a Facsimile - Not an original
)( etOfr[el Fle,'CpL CIi me N z 12 i-2 Pv.2- 1-4 --- _ 13 o-.-nett
4 Of 5
C'ardniember Agreement
C MA 12762
ACCEPTANCE OF THIS AGREEMENT
..This agreement governs your credit card aCools d with us referenced on rite Card Call ior
cantainirig the card for this a ccouni. Any use of your account is covered by this aoroclDUfit.
Please read the entire agreement and kvep it for your records. You authorize its to pay
for and charge your account for all lransarlin,is made un your account. You promise to
pay its for ail iransactiiens made on your a,:count, as well as anylers or finance charges.
If this is a joint account, each of you, logciher and individually, is responsible for paying,
ail :imounis owed, oven it the 3scouni is used by only one of you. 'Ale may require iha!
ynu pay the fl!t nmount awe"; wiihoul first tskfrg ;ha ?ttherprrsonis) to pay.
Please sign isle back at your .:arrlwil anvcu recu;vu;(.'iruwillbe bound by this agreement
it yru of anyone authorized by yet) use your accoum for imy putliono, even it you don't
sign your card. Whether you use your ar,couni ci not, youwill be buund by this agreement
unless you cancel your account within 30 days after receiving your card amt ynu hnve
not used your accotriu far any purpusc.
Throughout this agreement, the words 'we", "us' and "our' rnpen Chase Rank USA, N.A.,
If,e issuer of your credit card and account. The words -you", "your" and "yours" mean of
Ilersotis responsible (or complying with this agreement, including the person who applied
fur the account and the pursuit lit Whom we address billing statements, as well as any
person who agrees to be liable on the account. The word `card-means one or more cards
or other access devices, such as nccount numbers, that we have issued la hermit Vol]
tm obtain credit under this agreement.
USING YOUR ACCOUNT
Yollf account is a r,olisulster ;)Ccouni and shall be used only lot personal, family at
household purposes. Unless we agreo or it is required by law,we will not ha responsible
for merchandise or services purchased or leased through use of your account. You
promise to use your account only for valid and law'iul transactions. For example, internet
gambling may he ilingal in some places. If is not cur w5pansibility to make sure. that you
use your account only lot permissible Iran saclion%. and you will remain respon;ib(r. (of
paying for a transaction even if it is not permissible of confnmptated tinder this agreement.
Types of Transactions:
Porchas::s: You may a>+: your card to pay W uuods or services.
Checks: live may provide you cash advance checks or balance transfer Chucks as a
way to use your nc rount, We also refer to them in this agreement as a chock or checks.
You may use a check to pay for goods or services, to transicr balances io your ar.count,
or for other uses we allow. But you rutty not use these chucks ill iransll'r balances to
tlus account from other accounts with its or any of our related companies. Only the
person whose name is printed rn ifs shock may sign the check. Cash advance checks
fire treallid as cash advances ;'n'! balance transfer chucks aru treated as balance
transfers exrept as noir:d i ; tl•ds ayrr.'olnew or any ntferwe make to ynu. We may 1rral
checks that we call crm•:•na:. a checks as balance transfer chucks. Hnwever,clufuks
that we ctill u, : venicncr; ri,:• , ind that we indicasrdtoyou are subject in the turns
fnrro-di,dr, s,ruaybrlr cried;asashadvancesandassessedcashadvancerates
cos.
rs: Yg: r . , antler balaut:us from oihrr accounts or loans with other
card :::n a; T16. > :,Jfns m this accm!nt, nr uther hal:utce transferswr allow.
Co! you mt .i trrnsie, rdancrs to this acCAunt from oilim ar,ccunte with its or :my
qi 1,:;r rol.:::.. -.aoll)hnies. li -, ;onion of a requested balance trnns{rrwill exceed your
2vaileble ; fan., f,- 'r (ucvss a partial Wonce trait I • ;:p ;c your available
midi1 lint;
• cash fill,::- : You may ,our card to gel cash from autc!?,:.1'= tiler machines, or
bm;t • easta,aions at:cupling the card: or to obtain _,s checks, foreign
currf y e.:r•!ers, wire iraosiars or similar cash-like ; a[ !a obtain lottery
tickD•.c, - 0aminq chips, race trackwagers sr for simd, fail v.,nsactions.Ynu
May third pally sac ice to make a payfnc,,t on yours. f and bill the puy nL,.
to fhi a
•'ver+ . allies: II Y-:u have an eligible rhea;:-, occou, ilh oil DI our rely :_
: il,, 1v link Ibis account to your check.;..:: a--cottnt w -h our :elated bank c
,.. 'rift on tl':,t ;,hr,cking account tw r1, irons : i this -giremuM a:
yat!r '.^< ,ctmant ai!r 1. "'01i,
bil!inr:vclf deriumanageyeur.accoont,v: ti:natldoporicds : tledl.J•'•q
cycira+:° , iyclei?a.:;hrnximaie!y()herr,,: nytlh.for nch,,;:r 'Jaffna '
'DIM a -ace l ^ n h ;f;,:!) cycle (hat cliff!; io cn{h. Your aecoir,lt will iha•:: r=
;.ilhrtg yci" trig in each !ondar moot, wbeu • „ ea there is a billing sratenl^ '
!:rr that bill,. ciclo.
Atillil i ': ,;rs: If you someone to us!; :rn • ;;u:aunt, that Perrino will bit an
authcn r you stay , lost an .:dditiona! list! by an aulhorizrd user ;•h
yowaccn,;: 0youdoso, l_ tccOuntmayapI)!::;; credit(oporlofthatauthor.-
user. You s. .r (bil)k can,ftr!!y before allowin_ to baccr;r an authorized e,
(incausu! yn , of allo.vin ; ih person to use t : tit as ycu can. You will fen.
esuunsible'-•rrreIlse of;or1C000manduar.! ;ndonyrnrar.cnuntacrnru :
;r, the form, !,is au!:' now. This includes yr.:. :s;:: ;silo ty or pnyinrt all cha !c
o:? your ac, • . ,' !nag,, ; rill atilho0zed user.
You must is i:. totininate on authorized u_sr's permisssur, u; use your necounl. if
younotiF; t,;no,t lose tile account and/or issue a newcar=.lrft:ards,AillIdifterent
account fit;,, er You sitculd also recover and de,troy any cardr, checks nr any other
means a! a:.:,!s, in year ?rrcunt Iron that auti!aus:.':! ,.>ur
Credit credit lin^ appears on your bill. ^ r!,rrertls. Wv may a;> refer to
l,mii. Your billiwj statem , Oso show that ant:, a Puffins'
:y Ile used hrr rash,-,dvtnces. C; -anees,including crab aditan,_
r .l against tae case- advance pi 71 yair credd line, and all other
r.: r,1, or armed against ye' . credit Ill, .-, art responsible for keupinq track
?,.: 01 6
of your account balance, including any fees and finance charges, and making sure it
remains below your credit fine. If your account balance is over your credit line for ally
reasoo,we may charge you an overfinhit Ion as described ill this agreement. We may, but
are not required fo, authorize rhargrs that go river your credit fine. Yet: must pay any
amount ovr.r your rrnrlit line, and ynu most pay us immediately if we ask you to. This
agruement applies to any balance on your account, including a.-,y balr•nre over your
credit line.
At our disctrtion, Lve may increase, reduce, or cancel yr,.rr r.ri dit tine, or the cash advance
portion of your credit line, at any lb!lu. However, i( yell have asked us flat w t10 so, we
will not increase your credit line. A. change to vour credit fin! vdll ^u' :!truer yuur ubiigaucn
,n pay us.
International Tracrsactiots: !nternational !ransactiolts iiu:bnfe r asncti;a ii'.al you
na'tc in a foreign currency oriha! pct,,,,ake outsideof rte United Males :;f Atnr;rca evert
if it is auntie in U.S. ¢!e':!urs. if ,i:tit make i !rsnsacrion i.. faf_.JJ2l -_urrencv 'F.;a
International or h? s!vr Ord ln!?rnr.:ignaf, inc, will con?c?: the :ransa:ai;n inio li.S.
dollars by using is ruspeuivu currency conversion proredurrs. Tito uxc hinge rare each
utility uses to convert currency is a rate that it seloc:s either Iran iha Congo of rates
available in the wholesale currency markets for the al;,pficahle procil data ¢xhich
rato may vary from the rate the respective entity itself receivesi, or the
government-mandated rate in effect oil the applicabla processintt date. The rate lit effect
on the applicable processing date may differ Irom ilia rate on she data you usod your curd
or account. We reserve the rigl±t to charge you an additi-unal3% of the U.S. dollar amount
of any intr.rnalinnal transaction, whether that liansaciian was originally node in U.S.
dollars or was made in another currency and converted to U.S. dollars by lrsa or
MastorCard. In either case, the 3% Will be calculated oa the U.S. dollar amount provided
its its by that oulity, The same process and r.harfln s ntay apply if :toy international
transaction is reversed.
Refusal to Authorize Ttausactions:'vvVL, mav, but are nth required io. uec!ir?e a uansocil. on
on your account (or any of the following rcamms:
because of opt rational considerations,
because your account is in Jufuuli,
it vie suspect Iraudutent or unlawful activity or,
in our discretion, tot any other reason.
We are not responsible for any losses if a trans wiinn do your tr-caml! is declined for
airy ronsol, either by us or a third party, oven it you live sufficient credit available.
Fall online transactions, we may require that you register your account Lvith an
authorization systern that we select. We will notily you it we Lrrrns you to register. It ynu
do not register, into a:ay dectne your online transactions.
Refusal to Pay Clieclts: Each check you write isyocr fuquest lot funds, Whenv:e receive
a check for payment, we may revievi your account to decide whether to authofze that
check. We may, but are not required to, reject and reurrri unoaird is check for any reason,
including Ihr. following examples:
We or one of our related companies is the payee o:: ll:n ,:1.. ;.:k.
Your credil fine or cash advance portion Iii your crrit l; . .as heels rxct:nduti, us would
be exceeded if we paid the Charts.
• The chock is post-dated. If s post-dated checl; is paid, tc'.,thmfi in winther check hang
returned or not pavi, wv are not responsib!e.
You have used ilia check alter i'he dale ::pecilied on it-
You alu in dofalrlt or would be if we paid 1111, eltcck.
Lost or Simon Cards, Checks w Account Nombr:is: 11 any card, clfeck, acceu::::.n!abui
or other means ill access your account is Iasi or stolen, or you think son e.,- :.•ed of
may lists them without your permissinn, ynu roust noti(y its at once by c P.rrHl fill!
Cardmentfhrr Service telephone number sIlw to on Vent card or bitting stairme, !k; rot
use your account after y.^,a rarity us, eve: i ', our card, check, ac ro"oA numb". c,
gleans !u access your a(;ccu ,l is found z tinted. Wa miry ierfiimuie of
credit r:: iviinges when yn :.,;:fly us nl acv ,ss. theft or tuna tthn ;; er; rise slang t : ;u
account.
You may be liable it there is enauthorizo; I,-u ni your accanni In!• ,,;Milt You r;.ccive
no benefl, but ynu will not be. Futile, far r than S5010 of such ,usaeiruf sad you
will not be fiah'_ for any such lransocho rtade alter you notify u.: of the k "'s, l ,c! or
unauthorized usu. However, t'nu must irle10'. for its the anautharizot! ::harfres I--, •.vlnch
yet, received n:.';enefil.
vJs ay requir utf to p: • us inform hr{t ! f ,,I:( wl ''„ ,,a:eJ.
We may r.?o .!.urC yr. ... curnpl/ "'I't file
inuestlomion.
PAYMENTS
Payment It15tr:ic!:crts: yo::, billing sta'.emeitl and :cun+p:myi envelei;t-
;ncfud+:
instrucliais you must lollo,. !or making :u:,•matts ;w is foci , dntft rime by
which we must receive the payment.
You agree top :!s autounis you uwr in U.! Jollars of: -' un lull-'s t;• dnpusit is, is If.S.
financial institution or thn U.S, branch of r e(eign finan6.-,I mswurinn usin+l a payment
Cheek,mD•icyonleraraummatiedrhltt' :?= 7lhvproc ??^?'orhongrndbyyunrfia;nrial
instihRigr, rile ;i" col accept cash pavn •rls. Your re.:-! nvaitahlp
cir,4f n :•• flat be
festorod for Im to days after we regal eof paya?r •
Any payment of ether form of pa'- , ! which y d to us ' ,ass a: fcli
halanrc that is marled"I!aiti in hull" or v: .',nulr nai ,flea of that y:' . n1hern,t.sc wilder
ill full ra,sfacttun el u disputed amomn; _o-l,her.zi pa-melts), foul:; - :,ant to Its a1 the
condili :not payme,ls address I,strd:ir n!ohth3v, s! -:,mon?.lrc r1,• '!'de a" our ri0is
regarding such pb-;VlIIs. Fe: exampiu, :' h Ill : ,!'here is cc vaiiJ dispute or it
any sut.l, payment :._. recutved it any othr; dress. we ; acceGE Iha payment and you
will still owe ow y r,.mainina balance. V : , ay re:usc to accept any such vuymont by
wfurning it to ail casilmo it of by r ::.,:,?yt •.,, ,c . 11 ofi•el payments h: I ,.., t;e
should he sear. c !Le raqutar onymeru aI!T s . wlri nn your rronfhiy s!a,._,.....
EXHIBIT
r''
We reserve the right to electronically collect your eligible payment checks, at first
presenununt and any representations, from the brink account on which the check is
drown. Our ieceipt of your payment checks is your authorization for us to collect
the amount of the check cluctronically, or, it needed, by a draft drawn against the
batik account. Payment checks will be coltacled Llectronically by sending the check
amount along viith the check.., rutting and account numburs to your bank Your hank
account may bo debited as early as the same day we receive your payment. The
original paymr!nt check will be destroyed and art image will he maintained in our
records.
Miuimunt Paytoww You agree :c pay at least the minimum payment due, as shown
an your hitting st;:tumew. so that we iLcelve it by the date and time payment is due.
You finny pay more than the minimtnn payment due and may pay the full amount you
owe us ilt poly little. it you have a ;;tanr.L -!In! ` :;ubiect to linance charges, thrt
sooner you paylis.tile less You will p:tyinfina;:ce"hargeSLecauselinancech.l,us
accrue on y ow balance eecii d
Your billing smiemeril shin• your beginning ,alunce and your ending balance (the
'New Balance' on your billing statcoie,nt). h the New Balance is Si0A0 ur less, your
minimum payment duo will be live Flew Balance- Otherwise, it will be the largest of
the following: 510.00; 2% it' live. New Rahutre,; nr the sum of 1'/ of Ilia New Balance,
total billed periodic rate linance charges, and any billed late and overlimit fees. As
pan of till; minimum payment due,cve also add nnv amount past due and any aoUwm
over your credit line.
Payment Allocation: You agree that We are authorized ga allocate your paymunls
and credits is it way that is Rust favorable to or cunvenient forus. For example, yotf
authorize us to apply your pavnlents and credits lit balances with lowe(APRs (such
os promotional APRsI belorf, balances with higher APRs.
Credit Balances: You may request it rolund of a cretin balance at any limo. VVe may
reduce the alvisaitl of anycredir balance by the amount of new charges or fees bitter)
to yoor account.
Automatic Charges: You may authorize n third party to autuntalically t:hafgL your
accnunt lot repeat transacouns ftar exon;ple, menthiy utility charges, memberships
and 61sura ICO pr'efniur'nsl.11 automatic charges are stopped iar any reason fincluding
because your account is closed or suspended !or any (ease[)) or your account
number changes, you arr. rr,:;ponsiblu lot notifying the biller and paying these rhargos
diructly. If your account ntuacer change,, we naty. but are not required to, pay from
your new account number charges that you authorized lobe hil!ed voyeur aid ar.reunt
oombf,r,
Promotions: From time to tine we easy offer special tarots for your account. it vvu
du, we, will notily you about the terns of the. offer end how long} they will be in eliect.
Any pron'totion is s'objecr to she Icons of Iliis aElreemerl, as modihed by the
promotional oiler.
FINANCE CHARGES
Daily Periodic Rites and Alienist Percentage Rates: Your annual percentage Canes
("APRs") and file Corresponding daily periodic ra! a ate listed on the Rates and Fees
Table that is at the and r:f Otis document or plc Ided separately. To gel the daily
periodic rate we divide ?R by 305, kind in clfert always round up aI Cie fi h
place to the right of Ilse c d huint.
Variable ilales:Otte of r. _ P.rhit I apply,Inyc^raarcount -tiny vary tl4;r..lhit nges
to ilia Prime hale. Whe .;e an APR that with changes to Prone
Rme,we calculate the A. adf;ing a InarSi?, to .i a Prime Rate pull!is`;,rl ui Fh^
bVaNSY;rrr.lot;nialtvanb!;•;',`!ssaaysbefore it =ngDateshownoa 1billing
statuutent, free -O.-inhe R,af: !h;: %lighesi !U'S . !into Slate published in 01v Iv!oriey
Hates section Of Yhr. VVo ' i trrwl, If TA" - ..: tree(.ioarnalstops publisher. ;
the Prime Ra•v,:v will . t:.z _r:asar referf .., r, it mid inform you Oil -.l i'
statcotet t ar of tit ep,.,
A'rnargin is ;la • stay ?itj to lh i`:;n!e ;isle to calculate :l,° '„ ..
"business day' is a. v Ihn an ;i weekerrt or lederal holiday. The
Fees'rablr rows v + 1 r anc y, are varliio.a Cities. R also lists the i
each va ial rate. any;; daily perm-_ic rrie and corresponding APP,
Two businr. days t.-fofe th,: ..ieg Data shown cu your billing statement, v;e r:;a
what file Pre: e flit a is. We Ili .d II,si appfica!:'e viarght to that Prime
the APR. ?r_ daily .i-dic r . iii..li nt„ri ,, .!'t 61ted obove.
It out calcilfiuon rc . ;l!s in a r t t:; ;h (.ally p -^:r`_ rate (ruff) tile lit e, ity
;I
cycle bee ... th^ ::c Rat faire) t: -: r.: Into will apply =s -f i
day of yc ., !frig a that in the t .dinar month in which vie
calu'fdBne•. It !!:err riullcincreases, yav hvi!l have to pay a higF;:r Lor
finat:ce charge anal haw_- ; a7 it highLf -:l inmm payment-
G- fault Rates: Your s al_ vary it 1^-" a,,, default under this aereement
c: :any other a:;ruo-nien; yru .1 , %'Ith ns nr ,v c! • felatud culnpal• e•. Inr any of
!aROWrnq f;',:
r,%e do not r,rii;ve,' c.rv anent di,.; is av:..::. au this account or any other
accor•.:l or lear T! I !lie min main po-: ant due by this tins and time
du a.
You es rev: ou: cnxi:l title zctafnl
You mar _ z aymt,ril :c its t. act hortered l•y ycuf bank.
It any of these events occurs, ay increase tl a APRs (including am: e".feria)
APR) onall b-la::ces(excludi: cC'rajtadvances)tip to amaximum edefault
rote stated ! he Fates and _r. Table. We may consider ilia following +aztors to
determine fault rate: ?ngth of time voter account has been open, ;his
existence...-mus.::essandi, .,`theta our:;unyoatacconnl; otherindicaliens
of your accoitni usage „rid a rice; inter[) acre about your other -is:ianslliits
with its or aril, of our r, rte:; os; and fn'crr::!ion we obtain Irv »nsumey
credit reports ohtau:< fro:[) c :freaus.' c du:auh rata will fake 4rt as of
the first day u' the ;; ryc ...'rh the d.!: ;r0i rrcurs.
H we decide not to increase: your APR even though (here is a default or if we do not
increase your APR up to the maximum dofaell fair! stated in the Rates and Fees
Table, we reserve our right to increase your APR in the event of any luture defauh.
We may in our discretion determine to charge reduced deiault rates or reinstate
standard rates for all or selected balances on your account.
Finance Charge Calculation - Average Daily Balance Method (including New
Transactions): We calculate periodic finance charges separately lot each balance
associaledvrith a difforcntctilegoty of transactions floc example, purchases, balancn
transfers, balance transfer checks, cash advances, cash advance checks, overdraft
advances, and each premotionl. These calculations may cointiinc different categories
with the some daily periodic rates. This is how it works:
Ar'e calculate periodic finance charges for purchases, bala,, a !i3nsfers, !:. lance
!ronslar checks, cash advances, cash i;dvance checks, and' ov.^.r iraft advances 1ty
nuhiplyinif the daily balance lot each of :hose cafsgnries!rv tee ;iaity pefi,;6ir ; a;:f
or cacti of those categories, aech day. 'roll may havu uverdrnft ad•:anr. s . Cliy II
you baud, finked this ar,+:muit is a clieckin.1;lccouni with lire n' ,,if ,;6tted'ca:%ks.
We calculate the pariodic finance charges larpurchases, balance translors, balance
transfer checks, cash advances, and cash advance checks cnbj^cl in 3 fironirtional
ra!c the saute way, but we use the prurnulional fate.
To get tho daily balance for each (lily for each r.alegur;:
We take the beginning balance for that day.
We add to that balance any new transactions, !cusp other chanctes, and nul:a
adjustments that apply to that categary. We add it new purchase, cash advanr.e.
balance transfer fit overdraft advance, if applicable, to the daily balance as Of the
transaction date„ ar it later dote of oil[ rhoice.We add a new cash advim::f: check
or balance transfer check to ilia daily balance as of the date the caxh advance
Check or balance transfer check is deposited by a payeO, of a !;)ter date of Our
choice.
lNe subliact (Join that balant:L• ally paylrlent.:, credits, of cfe it edpislowtvis [flat
apply to that category and ilia( are credited as of that day.
We treat a credit balance as a balance of zero.
To get the beginning haintivp for each Ca:cgnry for Iii: aunt Cloy, v?e. ado Isle daily
periodic finance charge to the daily balance. If more than one daily periodic rate
could apply to a category because the rate, for the catugarr may vary based on the
arnount of its average daily balance, vim will use Elie daily periodic rile that applies
lot Else average daily balance amount at the end of the bi:ling ryr.fe 'o talc!.Ia!e dir
daily periodic finance charge each day, This agretmenr prcvv!es 'or daily
compounding of finance charges.
To get the total periodic finance charge for the billing c,•t:!e, w•r! add 01 of Ilse daily
periodic finance charges for each category for each day firing (tat billing cycle.
However, if any periodic finance chattle is due, we will charge you at least ilia
minimum periodic finance Charge stated in ilia flatus and Fees Tablu. It it:s nucussary
to add an iMitional amount fo reach the ininimum finance r.har;e, We add that
amour'. ii•a IsMance for purchasLs made dwing the billing cycle -
The .:ai linance charge at your accnunt lot n hilliny cyrh will hst f is seta of t,c
peiodic finance charges plus any transaction ice finance charges.
rcrPa chrnagorywecadrulamanaveragedaisybalanceI` udingnew:{ansactinasl
for the i.:I!inq cycle by adding all your daily balance: a, dividinq the) omeuni by
the nur:Lcr of )lays it tae tilling cycle, if you multiply the !reraga daily !;alat.ra far
a c3tegcrybythe applicable daily pariodic (airs, and muliiay the result try the, number
of days in the billing cyctf, the total will l!qual (Ile periollic finance chafycs for rl:et
haLnnnt attributablo it, IIIi;t hittinu cycle„ exrepi iar minnr varianiuns ff; c -n mudding.
Grafts Period and AcNoaf of Finance Cbarllt s:We accrue periodic iiniloce chaiucs
rnl : 'ransaction, In innnee charge train the data it is - (.!d to your J;: ly balance
anipaymenlinf;:ll'; >=e!vedonynuraccnunt.!lowuver ardenor cha-e!!parin(lic
oancechargeso•• e:;rchasesbilluddorisu!abi0lnq..yc:e if Wareceivepayniant
,! your Now Hale, the date and time yr,::r mir.[murin niiyinent is due and wo
n!r.uivud payment sue New Oa!ancu nn }:;uf fift US J!l iin4) ltalilini L'nl !ly tlii
date and time your ant was (Inc. This al, -ntinn or : r re periof` i 430es rnty
!o purchases and de rapplylubalanceuo:cfurs.baL r.e:ranslar ?eck:.cnsh
advances, cash adv; trio checks of overdr;ih dvances, applicable.
Traesaclion Fees for Ca <ii Advances: We tea; charge tr. tslt : o e trip, is)
the amount stated .r..,.L Hales and fees Tai:!,: for c,:s:i a.. ire i.!• s zerf cash
!,latices.
add(:' a, if you it third party service make i on 'l
sctoce chaffy ivit10n1 Its this ac -oil, wL 11.r ... ante ii n h't!
Ice the payment,
i hose transaction. s e finance rlmrgcs. Wu add . ae to fill: nrV fur this
aelated category it . • lh;a transaciimt date of nlic r advanc . mete,
rapsaction fee for , r ash advance would be added tc our cash a... r,ce balance.
TrarisaclianFccsfcr;.il;tneeTransfers:Wemaycht: yu1;;tfansferlee
in the amount state, the Rallis and Fees Inr :lance u ii- chocks and
glance transfers.
These fransaction I; ` ::re finance chargec 0/e add th^ fee r,- t the: ! :Ice Inr live,
:Hated cetogory a . !he transaction date the Irl:r cc rr . Sk example, a
transaction lee for is ho!anca transfer wc,be ; ' r;ed :P, !r ce transfer
balance.
OTHER FEES AND CHARGES
Ate may charge the f7Hewing foes- The amecels of these fee ,. are Ished in the Rate.;
z d ices Table. TtiPse fees will be added t :: bnfarco fnf r rr •s n?ad- daring
Isis Idling cycle.
f.nntfal IvIambershi° Fee: If your actounl hais an annual merlin a, it Visit ha
)Ted oaeh year ;f im_•?lhly inslailrnems kAs stated in !ilia Rate rea3 Ltblol,
Aii:iher„rnot;s .asraccoum,andy. ur,!Gpay if whrn.. _ilie.^nnsal
Page 7 of 6 , ,iii
membership lee is nom refundable unless you notify us dial You wish to close your account
within JU days of the date we mail your billing statement on which the atutuaI nheribershill
lee is charged and at [tie same time, you payyuur outstanding haiancr. in full. Ynur payment
of the annual membership Ice does not affect our right to close your account nr limit year
right In make ransactions Cn your account. U your account is closed by you or us, we
will continua to charge the. annual membership fee until you payyouroutslanding balance
in full and terminaw your account relationship.
Late Fee: 11 wo tin not receive ;it least the required whiiinom payment by the data and
time it is due as shown on your hiding statement for any hitting cyelo, we may cltargc the
lair. fee shown in the Rates and Fees Tnble. H the late fee is based on a balance, we
r.alculato the. !ate fee using tilt' Previous Balance on the current month's statement that
shows the lair, lac. This balance is the same is the New Balance shown on the prior
mundt's siammenr for wnich'„te d :fl a,. _.eive at East the required minimc'•]t eaymont
by the date anti tittle it was dal.
overlimit Fec:11 your account Leiarce is uv,?r ynur credit line at any time dcriti a billing
cycle, even if only for a day, we may charge an oveflitnit fee. We inlay charge :his foe
even if your bitttnce is over the credit line because ul a finance charge or fee we imposed
or a transaction we authorized. We will net charge more than One ave(limit ice for any
billing cycle. But we inay charyc an overlimit fee in subsequent billing cycles, even it no
new transactions nine made on your acruunt, it (our account baltrnce still is over your
credit line nt any time during the subsequent billing cycles.
Return Paymrm Fee: If (a) your payment check or similar instrument is not honored, IN
an automatic dabit or other electronic payment is returned unpaid. or Ic) we must return
a payment chuck because it is nct signed or cannot be processed. we may charrie a
return payoront fee.
Return Clleck Fee: H {a) we Stoll pavmenn on a cash advance check or halance transfer
check at your ruquest, or (bl we refuse to pay a cash advance check or balance trar,<.fer
check. vac may charge a re4ura ",heck feu.
Administrative. Fees: If you (,quest a copy of a billing statement, sales draft or ether
rocnrd of your account or if you request two or morn cards or any special services (for
uxample, obtaumrlf) cafds on art uxpediled basls),we may charge you for those services.
However, we will not charge you for copies of billing statements, sales drills or similar
dricuments that you request far a billing dispute youmay assen against us under appficalk,
law. We may charge, for airy services fisted above and other services we provide, the
fees from tiro:: to tittle in effsri h•'ha! :^ r: offer the service.
DEFAULT/COLLECTION
We may consider you to be in defaoil if any of these occurs:
We do not receive at least the minimum amoantd•te by the flatn and time due its shown
on your billing statement.
You exco.,d your credit line.
YOU fail to comply with the terms at this agreement or any agreement ',.,vh one of fill,
related companies.
We obtain ittlormation that causes us ir, believe that you may he unv of unah!e to
pay your dabls to us or to udte; s cr rr;^
You file for ber,kruptcy.
You becnme incapacitated o. '.n _ eveoi of your deaif
If wu consider your account to bt, dr.I;rull, we may close your account without notice
and requirn you to pay your unp::id lie!anru inin ediale!;. Vde olsontay require you to pay
interest at the rate of Iwo percent i2%) a month on the balance wl:cn we deem
your account to bL• six or circle b;!i;,•.O c'ycle's past due.
To the extent permitted by law, t,. are in dtdaul[ Lecr:, :,c you have faiifi : to pay Us,
you will pay our collection costs, hers, court caste, and nil afher expenses of
enforcing our rights under tilis ` t--Ilert.
CLOSING YOUR ACCOUNT
YOU may close your acr.o,:nt ::: ;.. !:ale, if ycu adl us to c:sse your acct',' it, we may
cquire that you confirm your rt:r;urcl in vvrtnq.
L, may Anse your account at a,:y time or suspend -jow arc-?it privilegr:s at any time for
]y reason williout prior •lolice ercrpt ns reglfirad : ptlf:"able la'N. 11 VJP Close your
.account, we will not Ili liable n, y0?. ?or ?ry cansegt cos: f r0ing firm clesins your
:account or !: uspendin.. atr rr , .... •.;es.
voo or + close y,,. tu:our , Y[ f rind any dull u : .. ors anus; mmcttafely Stop
._::ngyour.,-r,;unIa Jd„stroy?.llchcckser0!l:,-r,ranstotrcccssyouracr.ount
return than to us LiPU ruqut.., tc., wtli c0rminc:f, . • rEsponsib!e Ica cbar,!cs to yotir
::count, pi On it they made ;r crct:SsLd : h:•' yo!.; arcount is closed apd you vvill
fv,iurer' to f>dy th stand n;.:. alrnc'e. all y' r accnrdlhg to the terms of
in ad..r;,: n, to thin al!ow'ad v, !dt V _•t! :nay require you to pay t1
astandutL Ir:fancO , .'lately c. zt ,try tittle aftt ,w;r ar.coUnt is closed.
AU8ITRATO;a AGREEM.. NT
PLEASE RE.AU THIS P o-CMf !?T CARE,`ULI.Y. IT PROVIOE'? THAT ANY OISPUTE fJlAY
RL-SOL! I1 BY BI .':JGAr'iIRAT!C"1.ARBITRAT10'Jn;PLACESTHEP:GHTTOGO
COURT 4OU WILL NOT !3E '•!3L[ TO BRING A CLASS ACT'.0P1 OR OTHER
°FPRCSENTATIVE ACTION IN SUCH AS Tf!•-! !N THE FORM 01A PRIVATE
,.l101iNEY GENERAL ACTION, ':'111 YOU B_ ALLE TO VING AN,! CLAIM IN
ARBITRATION AS A CLASS AC -: OTHER R` aR'rSENTATIbi: ACT:D:. YOU WILL
NOT BE ABLE TO BE PART OF LC SS ACTION CRC- HERREPRESFt;:VEACTION
BROUGHT BY ANYONE FLSE,' REPRESEN':.f :Ft A CLASS A(7- On OTHER
REPRESENTATIVE ACT ION. IN THE ABSENCE OFT:, "BfTRATiON f.t RELMENT, YOU
AND WE A': A'' OTHEP'V)IS! HAVE itAO A RIGHT OF. YPpRTUNITY TO Pc'NG CLAIMS
;NACOUR' cEFOREf,JI :`SEOR J ` ,,AND/ORTOPF,i!11CIPATE On BE 2, PRESENTED
N A CASE 1 ILEO IN t ;.tT BY D-HERS (INCLUO JG LASS ACTIONS -!ND OTHER
IEPRESENTATIVE ACTT ,NS). OTHER RiUHT3 THAT YOU . JOULO HAVr 1; YOU WENT
'D A COURT, SUCH AS DISCOVERY C ° THE RIGHT TD APPcALTHE 1 :`SIGN MiAY BE
ORELI -ITEO.EXCEP"ASOThrRI, FLOW THOSE "'WAIVEO,
Binding Arbilratinm. Tins Arbitration Agreement is made pursuant to a iransa cult.! invol-Ang
imorstale comntorce, and shall ba governed by and he enforceable under the f lder•I
Arbitration Act jlhr. -FAA'), B I1.S.C. 51-Ifi as it may hr. amcndrd-This Arbiuanmt::grcrnuam
sets forth the circomstarice s and procedures under which claims (as definer! balahe•i may
be resolved by arbitration instead of lining litigated io court.
Parties Covered, for the purposes of this Arbitration Ar!reellleill,''!.•C and"ouf' also
includes our parent, subsidiaries. affiliates, licensees, predecessors, successors, assigns,
any purchaser of your Account, and all of their officers, directors, umpluyer!s, agents,
and assigns or any and all of them. Additionally,"we", "us" aod'uur' shall include amf :hind
party providing benefits, survives, or produris in connnc:inn with tilt- Account liach+ding
but not limited to credit bureaus, morchunts that accept ony credit device issued under
the Account, rewards programs and enrollment scrf:b;as, insurance companies,
debt collectors. and all of thair officers, directors, einntevees. a enis and re pre so fitanvesl
i(, and cr;ly i!, <_uch a ti!ird tinny is named I:y gnu as +; cr!-ae!gr+d;rnt in:;ny ia,?imypu ;;.,gin
aga::nsf hrs.
Claims Covered. Eilha( you or we ii"we, without thin. od:e; ; cunscm, cluct uiatidatury,
binding arbitration of any claim, dispute or rnniroversy by either you or its aclainsi the
other, or against the employees, pafents, Snbsldiafic5, affiliates, heneficiarie.s, agents of
assigns of the other, arising !fell) or relating in any way to rile Cartbnen]bor Agrees at
any prior CardrtfemLer Agrecmunl, your credil earn Account or the advertising, ap; fication
or approval of your Account ('Claim). This Arbil(mion Agfn,mem yovrrntc all Claims,
whether such Claims are based nn law, statute, contract, regulaiiam, efdifinee, tea.
common taw, conslilutional provision, or any legal thrnry of law such as respondent
superior, or any olhef leoal or equitable ground and wheth,f sucl; Claims Seek as mmerfies
money danstges, ponallies, injunctions, or declaratory r,r cgaiiablc relict. Claims subject
to this Arbitration Agreement include Claims regarding file applicahiray of this Aibi:iation
Agreement or the validity of the entire Cardmember-Agfeeninty or arty prior Cordm!!mbe,
Agreement. This Arbitration Agreement includes Claims that nrosv in the past, or arise
in the present or the lulure. As used in this Arbitalinn Agree,ncnt, the term Claim is u)
he given the broadest possible meaning.
Claims subject to arbitration include Claims that arr. mad, as counterclaims, cross claims,
third party claims, iniefpledders or olhervrisu, and it p;trty whu initiates n pinceetfing in
court may elect arbitration with nrspecl in any such Claims advanced ;r; the favvsrat by
any party of parties.
As an i:xccplion to this Arbitration Agremnent, you retain the right to pursue ill a sal:all
claims court any Claim that is within filar coer,'sjurisf!icran a ui proceeds on inn individual
basis. If a party elects to aibirtrate a Claim tho aflihfatioawitl bo conducted as an individual
action, Neither you nor the agree to any arbitraliott u? it class ur leplesi;niativi! basis,
and ilia arbitrator shall have rte authority In lrncend on sttcb hasis, This means I`;al even
it a class action lawsuit or other representative action, such as that in the tunrn fit a private
atiorney general action, is filed, any Claim between its €etated to the issues raised w mwli
la:vsui:s wit be subject to an individual arhiiralinn claim if either you of vv o so elr!rt.
No arhilralion wilt be consolidated with any other arbitration proceeding vfithow the
consent of all parties. The only Claims that may be joined in an ind'ivid:ral aciiuo Order
this Arbitration At-reemmnt are (1) those brought by us against you and any i;O applicer.t.
joint cardmer-1ber, or authorized user of yr,:r Account, or your hairs or your Ittisiee in
bankru0ley rr (2) thee- brought by YOU odd any et'-applicant, joint cordme;rbef. or
authorized a ter of you: Account, or youf heirs Or your trustee in bankmptcy ar,ziiiSr its,
lniliation of Arbiitmian. The party filing a Claim in arbitration must choose o c 'bc
following two orbit alit',; administrators: American A. bi!rmion Association; it
rJ:!;coal
A;Lira! dun Fcn!n!. `hesu administrators are independurt lawn us. The adminisu:aur r1uu::
not towfs?t the arbitration. Arbitration is cunducied under the males of lie t,d
arbitrtiou adm:?islrnor by On iutparti:a third party ciasen in accordance with U;c r?. .
of 0-o sclecle;i ubivaiion m1minisir ter and as nary be provided in this Arbi!rafi?,-
Ayreemen ry arbitration lhuarifig Il:al you attend I:aR be held at a place chf;sec :.
tf;u arL•i: ar';ilratian adminisua!:;nvilhin thu':,deral judicial disrict in whirl: _
re ;i.ic T}c 'Iii C!: inr is filed, Or of some other ,:taco in. cvhich ymf and we or;,: ;;
w:i!iag. ^hlair: copies of the ctarent rutrs of each of the lsvu arlwl;Itio•,
about arbitratien and -itrafi0n fe:mss, anti inslmdic•ni ;,..
i-iitla!i _ ,?... n by contacting tin armrratien admiaisfr,:,_.s as lolloes:
n A;: <i`oe Associaticn, J:' 'Sadisan ;.;,cr.,. Ip, Nerr Yr!k, id 1'
;C Sl?E,V. -: -nvtro.adr.err,ElOC-'::l-1879;0,
IJ'
r::l Aft Furllrn. P.O. B- '0191, V _car)c.:, L4N 55-105. V,'.•b
r....r,. - . nn-com. EOU'I'^ :?':.
.: applicable i? A :r q!c.:.. ?:,•ai arbitrator evil! r. snL•e
;r vAili either be i vAlh at I.. _! ter ; oxporience o, a ,et,nnl
r arbitration w21 .. :oducl d .. _..; thin -.ival !:; prnrrrfufftS ,d
of O r. (ion admininlulmr are in nlf.:• In the ".C Ile arbilrnrou is `.'i:'C
doss those :. ldtires and rules f,. !nconsistun::Ath this ^ rjilration Agreemew in
r.•!rch case t' it cattle tit will preva1. ?hose pro-'t'; Jles and n, -'s may limit the amount
sscev? y!a to you or its. I nc arbitrato; :.ill apply ,. .able s::uslr,niive law
Isis!: FAA aad aplibuaLly +tatules ;.f irtitaGrr .,rid will honer claims at
taco-, ed at !a+v. You may r.Lonse to have it h:tar n.- ,rid bu iepresentnd by
Counse!.Thea .• eto,'wIlltake reason;'i:lestepslopraler:lct t.. erArcuentinformation
and ,titer cot ^Iial i:;formalion, it t.'r dint' the use of err; fs to prohihrl
d;r _sufe out. ^rbilralion, if re ves rid to :r: by y fa!or will
....:the pow to a party :ry ridm::tcs sr nth n r. -^r under
r,i;plicable law. d will not have the pc,vcr In av-ard relief t iyoinsi, or lot file benefit
of any person v,- is not a party to tit: proceeding. is file hz.: ebonies such rulief, tic
arbitrator may a:.ard purrilivc dam+:y: s or atiorne: `ees.'f: birator w1l make,
awdrd,r woti• n a?n need not provide _. ierllarit e' .:asur : cc' •;s rcgrze..•ed! y ? lr....
Upon a r,qur You er us. the art; vifl pro, a " it'! swtr.mrnt of ;hu rrasr.:s
for Ilia acv:] r_
Costs. We will n•sbur.sc you lnr Ill, .:;;-f arbitration !ii:. paid i;t yntr tip to
a!nelfnt of S509 :r,-•en rccnirt of prop, _: yment A. tdilinr :lY ,. a he my
-'age 3 r,I G CPA; %12752
will pay any fees of the arbiualur and arbitration administrator for the first two days
of that hearing. The payment of any such hearing tees by us will be made directly
to the arbitration administrator selected by you or us pursuant to this Arbitration
Agreement. All other fees will be allocated inkeepfng withthe rules of [he arbitration
administrator and applicable law. However, we will advance or reimburse fff:ng, tees
and othef fees if th a arbitration administrator or arbitrator determines there is good
reason lot requiring us to do so or you ask us and we determine there is good cause
for doing so. Each party will hear the expense of the fees and casts of that party's
attorneys, experts, witnesses, documents and other expenses, regardless of which
party prevails, for arbitration and any appeal (as permined below), except that the
arbiVatcr shall apply any applicable law in determining whether a party should
recover any or all fees and casts ho-1 another :)arty.
Eufurcanlan!, finality, appeals. Failure or env delay in enfor'ing ;his Arbitration
,agreement of any time, or w ron!,.ectiaEi •,villl any particular Claims, wilt not conslil[ie
a waiver of any rightx to require arbitrulion at a later time of in connection Willi any
other Claims. Any decision rendered in surd nhiiridon proceed{nn %vid be final and
hinding on the parties, unless a party appeals in writing to the arbitration orgunizatW11
Within 30 days of issuance of the award. 'file appeal must request a new arbitration
before a panel of Ihree neutral arbitrators designated by file same arbitration
organization. Till,- panel will reconsider all factual and legal issues anew, follow the
santa rules that apply to a proceeding using a single arbitrator, and make decisions
based on the vote of the majority. Each party will bear their awn fees, costs and
expenses for any appeal, but a pally may recover anyor all fees, costs marl expenses
front another Parry, if flip majnricy of the panel of arbitrators, applying applicable
law, so delerlnires. Al[ aw:arcl in arbitration will bra cnforcpable as prnvie, 0 by the
FAA or other applicable law by any court having jurisdiction.
S£verabahty, survival. This Armiratfnn Agreement shalt survive: (i) termination fir
changes in fete Cardmember Agreon:£ut, till. Account and the relationship between
you and its concerning the Account, such as the issuing of a Dew account number
or the transferring of the Lalanc£ in the Account to another account; Iii) the
hankraptcy of any party or any sint{iar proceeding initiated byyou or on Veer behalf;
and (iii) payment of the debt in fill] by you or by a third pwly. It any portian of this
Arbitration Agreement is deemed invalid or unenforceable, the remaininq portions
shall nevertheless remain in force.
CHANGES TO THIS AGREEMENT
'No con ch tgE tilt's agleam^rt a1 anytime, regardless of vJlietheryou have access
to your account, by adding, deleting, or modifying any provision. Our right [o add,
delete, or modify provisions includes financial ferns, such as the APRs and fees,
and other terms such as the nature, extent, and enforcement of tiro rights end
ob!igariooS you or we may have totaling to this agreement. Modifications, additions,
or deletions ar£ called "Changes" of a "Change`.
We will notify you of ally Change. if required by applicable low. These Changes niay
be effective with notice only, at the time stated in our notire, in accordance will
applicable law. Unless we state etlierwise, any Chance will apply to the unpaid
balances on your account and (e new transactions.
The notice will describe any riwd':t, you may have with respect to any Charge, and
[Ilia consecpwrices if you do or do not exercise those rights. For example, the notice
may slate that you may ilotidy I :n writing by if Specified dale it you do flat want to
accept certain Char,gr.s we n :- 'natling. It you notify us in writing that pee do ecl
accept the Changes,yourac-, I:.m-,ybeclosed (ifitis nor already closed) andyo:;
will bit obligated to pay your a :.tan:! ;!•; balance under tl)e applicable terms of the
a groomer). It gnu do not nw7 c: in wG;ink by (lie date stated in the notice, urif Vol;
notify u^ bill !hen use . au: C!:u ll af-wt the date stated i•l the notice, you Aril] be
deemer; ;a accept Ti as it due notice and to accel" and rectum all terms of
your ar:remcnl or.. C1:;,:,acs in nor notices We ha ,£ni you reoardiesS rf
whetl76 you lave . 'ss to pots ac-cuum.
CREDIT :':FORMA:
Wu may periadica!', : Lvievl vr. [ history by obtaining in!emati0n twill ere o
bureaus ant{ other:
We may re{uori inlc ion ;,heal and your account le cicilif bureaus, inrlulb nl
you( failure in pay i, n time. H y ;aquest additional cards till your account for
others, we may relic: :.cco„nl im, .: tion in your name as well aS in the names M
those alhe, peopio.
II you vie hat" .:,lun "'i , - .:!te infurmulion , 11 bureau, you -ray
varite IV, ns the m_r: :e address listtw nr billing statel?rr.
Please o.,'ude your Cr,unl nuaiber.Ir . r numb£raod a
descrilui cl the p pm If n ,L v, please ;:rovide o y of the credit blur eJ
report in - S?tun. 1 :Jll proraptly i'ivasligate the matte. Fill!, ii our inve Sligo I ice
shows ih i you are : roc will contact each credit I-reau to which we reported
[he inle:?nation and v.!i; ; eq uast they correct tiro report. li we disagree with you z4c:
our ir• rmn, r: z ve;h !r .:l you in :,;riling or L'. lute{. We will also notify l1 5
credit a[ rat :ou dispute the f ^rmation .:nfess et us know that you rir•
longer wspute the ir,fnrrna!; n.
NOTiCES1CHANG`eOF PERK;Wvi,,!, %iORMATION
Ile:v:fl sund cards, bi!l,ng srai£ . enis and otharnolices to ,ov,,i Ilse address sl:rk, 1
in our files. 0r, if thi. Is a ,o;:,! ., ..count, we can send b?t-.n., Eto!emenls el
to any joil.t acco: ll0der. id z to one of you will be c arsic'ered ntr;;
You and r ; ylj; emam c tigah!d on the accoun, ; :nu change your ndf,
address, C rclue ;r business telephone nundte email address fir a
ulncl to r clue -r,nrnlS cr 01hpi calicos , vu0 must 1101:`._ us
immediate-,: in w•i: - ad jfvi? >how" on your bii.3 , .?ement. We .. ,. at
ow Option. ;:ci: ;•lress run ections fionn the United Sl:,t as Posla!t.- -ice.
Yve.nay cr .,ar.l ?ji yr-•nr ar count. including lot co toning r: vicE or cal'?: '.on,
:a any ad -, n, :One ml"I 1cf i1S well as any ccih IJ .? )o nunlbr:..;ou
i.r nvidE '.e:
TELEPHONE MONITORING AND RECORDING
We, and it opplic able, our agents, may listen to and record yaur telephone calls with
us. You agree that we, and it applicable, otfr agents, may do so, whether you Or we
initiate the telephone call.
INFORMATION SHARING
You autticti us to share cortain information abort you and your account within our
family of compnnios, and with others outside our family of companies including any
company orarganization whose name or mark may appear on the cards, as permfncd
by law. Our Privacy Policy, which is provided to your when you first receive an
agreement and at least elicit each calendaryeartherealtor, d (scribes nor information
sharing practices and the choices you have and dirardenc Vnu may viva us about
our sharing of informr.lien ahrul you i i fl your nc,:all;;: r.luu,panies of
organizations within and outside at' our lami!y of cmmaaniz;,
iLLINOIS CARDNIENIBERS
i!!inois law provides (fiat we naav not share to?urmaiion ai)ost yuu r.•idu ::0utpani;r,;
of ether argauiza{ir.ns nucsidil of our tauniiy of comparfirs lilditss you aufhofizo file
disclosure or unless the disclosure falls under another exception in the law (such
as sharing information to precasts your transactions or in response to a subpeeno).
You hereby agree that, if you choose not (a exercise the applicable opt out deseribed
in our Privacy Policy, you will be doomed to have authorized us to sbaro personal
information we. have about you (including{ information related to any of the products
or services you inay have Willi any of our campaniesl witf+ cn+npanies er Other
organizations outside Of our family of comp ;nits
ENFORCING THIS AGREEMENT
We car. delay Enforcing of nor enforce ary of o!u rights under this nDrerment without
losing our right to enlerce them in the luture. 11 ony of flip tares of this agreernrinl
are found to be ur.enforceabfe, all other terms will remain if,, Ill!; lours..
ASSIGNMENT
We may assign your account, any mmrlunts yn11 owto us, ut any of our ri{{his and
nbligaffons under this.lljfe£mrni in a d)if l party. The peisrtn to whon we make the.
assignment will be entitled to any of cur rights [hat we assign to that person.
GOVERNING LAW
THE TERMS ANO ENFORCEMENT OF THIS AGRFEMENTAND YOUR Af:COUNT SHALT.
BE GOVERNED AND INTERPRETED iN ACCORDANCE. WITH FEOERAL LAW AND, TO
THE EXTENT STATE LAW APPLIES, THE LAW OF DEL AIM.ARE, WITHOUT REGARD
TO CONFLICT-OF-LAW PRINCIPLES. THE LAW OF DEL'VWARE, WHERE WE AND
YOUR ACCOUNT ARE LOCATED, WILL APPLY NO MATTER WHERE YOU LIVE OR USE
Till. ACCOUNT.
FOR iNFDRIvtATION
Ploaso call [he Cardmember Service tuleehono number c:n your card of billing
statement it you have any questions ahnut your account or Otis agseemew.
YOUR BILLING RIGHTS
Keep ,'his Nrlicr Far Future Use
This notice contains 5nponnn! inlnrmau)ao;th s1 yr;ln rights and oarrr.sponsibilides
under the 1 air Credr Billing Act.
Notify Us 1- Case Of Errors Or 0mesdinns Ah ra Your Sit)
It you thin your bill is wrong, of it you need I::ere information almot a [fansaction
on y--ar bill, vari!o us on a stparote shee.l at the Cardnlemher Service address shown
on your b Ring statement. Write to us as soc.- as puss{bie. We must hear Iron you
no later than tiff days alter we sent volt the Ibst bill art which the offer fir problem
aPpeared. You can telephone us, but doing sr will not preserve yon rights.
to Vila f i-trot, give us IbE 'ollow:ng mfarm; : ,,:
Y:. mG end accoun! m;ncor.
T::. :r amount al ' strsoecied err::;,
Oc_:•::;ethe erroran -plem,it You can,ivityyolfbelieve there is an efror.I1you
ii :!vi' re into -.,,lion,, [ •:; r be the i(,ol : oil are not sure aboul.
!fyet ;:. - duthc^zraustoualyo[ucnr,'cL,rdbill 3ulalna!irally Lot.your savings
or clw, ",,.wu accost,!, you caul Stop the pity) lent on any amount yc» think is wrung.
To step t poylqu: your letter trust react: _s al least three business days before
file -alto pa 1 r. It is chU'tilled to oc: '..
Yen rag! :s And Ocr tc ilities AI`.r, Rccci:,- Yom Vvrl NItilice
Wc -rsiccknowl? gu_r ':lays,,. ',,ssWe ha ochre Wd
efr by r-"'II. VJ!t•i! ,.l) e r:!:: •'llhor r.orr.r- ;c rrror fir art+'ain why
L'cira.rs t'.r !Al was art • ;.
Afli:r w;, rcccivr; your lu. lit, ?- Carrot fy to Culled. -,fly ifmr)Irrll y:IPu)stiol,, of
you as delinquent. We c: r cor:i..::a In hill Vol, , r file mmfow,; ou question,
ircitiding!uwncocharges, antitaecar. ..,Filyanyunp,--amrrsitn ;.i:;tyavfcredit
line. You not have la pay are questiorcd amount . ' :c we v •: iiga[ing, b:ft
you are s ;:f obiigmud to pay ll.,! parts n :, :fir hill Utz of nt.
! live fan:! 'hat we made a mist ke on yc:: you s : ! have. (o a.: any fin,n:uo
cha'g£s w r t cd io any quest;ned arnu',:a. if we Ill 1, ! make a •n r,o, you n;ay,
huv:: !n p;:v tin changes, a::d yuu •:,•:I lave torn,:., .;F: any missy„ laymr,nc: no
the es tic, -)r:;unl. In either case- Will send ve:j P. s!afem the amcu,il
coo ' :we ..d tf,, :^;e that it is due.
li : )ai; pay tc ;:mount that w_ it.: n.u ewe, w -lair report yc :.: dciingr.r,:[t
iiowwer, it our explitnifoon does nut :z.isly you and you to to w :thin 10 days
I ,lir^ us hat you still refuse to pay, wC must Fall anyunc we r epc. ; to Ih2: yea
vt stlveabowyour bill. Aod,wcmust ie:l you file ar u vr.mpol,.d
tip., J;+e must iwl n':ynir_ vm ra!rort vertu h'al file m;,nom. ha.. , . 'rt1 ber:..,r.n
US -:L'f: k finally is.
I -!r,-'l fol,n ;hest. e;lps, wit can'! nliecl Ile first S58 G-, s gr.£stis„rd
am, -?cn If wit bill teas correct.
.....: ?..'es far Cn'ail ..:r;l Purr.{Eases
Page 4 r. , 7 , h1(: i:'?E?
if you have a Prablmnwill, 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,
you may have the right pot to pay the remaining amount due on ilia property or services.
This right does not apply to check transactions. Thare are two limitations on this right.
fa) You must have made the purchase in your home state or, it not within your home stain,
within 100 miles of your current mailing address; and
(b} The purchase price most have been more then S50.00.
These limitations do not apply it we own or operate Ilia merchant, or if we mailud you tho
advertisement for the property or services,
Copyright X2007 JDAorgan Chass & Co. All rights roservcd.
Page 5 r1 t
VERI.FTCAT.ION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 54904
relating to «nsworn falsifications to authorities, that lie is Suan V. Montemayor
(Name)
Assistant Treasurer of Chase Bankcard Services, Inc. , a subsidiary of the
(Title) (Company
plaintiff herein, that maintains the records for and services the credit cards accounts owned
by plaintiff and he is duly authorized to make this Verification, and that the facts set forth in
the foregoing Complaint in Civil Action are true and correct to the best of his knowledge,
information and belief.
Aqec*
(S nature)
CHASE BANK USA, N.A.
Plaintiff
V.
SHIRLEY ARNOLD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010 - 6462 CIVIL TERM
CIVIL ACTION - LAW
NOTICE TO PLEAD
TO: CHASE BANK USA, N.A., and its attorney,
Matthew Urban, Esq.
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
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YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE
ENCLOSED ANSWER TO COMPLAINT WITH NEW MATTER WITHIN TWENTY (20)
DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU.
IRWIN & McKNIGHT, P.C.
By:
Date: November 29, 2010
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court ID. No. 25476
Attorney for Defendant
CHASE BANK USA, N.A. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010 - 6462 CIVIL TERM
SHIRLEY ARNOLD,
Defendant CIVIL ACTION - LAW
ANSWER TO COMPLAINT
WITH NEW MATTER
AND NOW comes the Defendant, SHIRLEY ARNOLD, now by marriage SHIRLEY
VALENTINE, by and through her attorneys, Irwin & McKnight, P.C., and makes the following
Answer With New Matter against the Plaintiff, CHASE BANK USA, N.A., as follows:
The averments of fact contained in Paragraph One (1) of the Complaint are admitted.
2.
The averments of fact contained in Paragraph Two (2) of the Complaint are specifically
denied. On the contrary, the Defendant is known as Shirley Valentine.
3.
The averments of fact contained in Paragraph Three (3) of the Complaint are admitted.
4
The averments of fact contained in Paragraph Four (4) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
2
5.
The averments of fact contained in Paragraph Five (5) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
6.
The averments of fact contained in Paragraph Six (6) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
7.
The averments of fact contained in Paragraph Seven (7) of the Complaint are beyond the
information and knowledge available to the Defendant. They are therefore denied and proof
thereof is demanded.
WHEREFORE, Defendant, Shirley (Arnold) Valentine, requests that this Honorable
Court dismiss the Complaint of the Plaintiff.
NEW MATTER
8.
The averments of fact contained in the Answers of the Defendant are hereby incorporated
by reference and made a part of this New Matter.
9.
The name of the Defendant by marriage is Shirley A. Valentine and not Shirley A.
Arnold.
3
10.
The Complaint of the Plaintiff should be dismissed or amended to name the proper name
of the Defendant.
WHEREFORE, Defendant, Shirley (Arnold) Valentine, requests that this Honorable
Court dismiss the Complaint of the Plaintiff.
Respectfully submitted,
IRWIN & MCWGHT,
By: c
Marcus A. c s
Supreme Co D. #25476
60 West Po fret Street
Carlisle, PA 7013
(717)249-235
Attorney for the Defendant
Date: November 29, 2010
4
VERIFICATION
The foregoing document is based upon information, which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904 relating to unswom falsification to authorities.
SH&I EY A. VALENTINE
Date: NOVEMER 29 , 2010
CHASE BANK USA, N.A. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010 - 6462 CIVIL TERM
SHIRLEY ARNOLD,
Defendant CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was
served upon the following by depositing a true and correct copy of the same in the United States
mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and
addressed as follows:
Matthew Urban, Esq.
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
IRWIN & McKNIGHT, P
By: Marcus A M fight
60 West P m et Street
Carlisle, PA 1 013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: November 29, 2010
5
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
CHASE BANK USA, N.A.,
Plaintiff,
V,
SHIRLEY ARNOLD,
Defendant.
PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS AND REQUEST FOR
PRODUCTION OF DOCUMENTS
Plaintiff demands that the defendants answer and respond to the following Request for
Production of Documents under oath pursuant to the Pennsylvania Rules of Civil Procedure
within 30 days from the date of service hereof.
Plaintiff also demands that defendants answer and respond to the following Request for
Admissions pursuant to Pa_ Rules of Civil Procedure 4014.
You are requested to admit the truth of each of the statements of fact hereinafter stated. You are
instructed that:
1. These requests are made under Pennsylvania Rules of Civil Procedure 4001, et
seq., and each of these matters of which an admission is requested shall be deemed admitted
unless your sworn statement in compliance with such Rules is timely made.
2. If you do not admit each of such statements, you must specifically deny each one
not admitted or set forth in detail the reasons why you cannot truthfully either admit or deny each
such matter.
3. Your answer, signed and properly verified, must be delivered to the undersigned
attorney of record for the Plaintiff within thirty (30) days after delivery hereof.
4. If you fail or refuse to admit the truth of any such statement of fact and the
Plaintiff thereafter proves the truth thereof, you may be required to pay the reasonable expenses
incurred in making such proof, including attorneys' fees, witness expenses, etc.
5. If, in response to any of the following statements of fact, it is your position that
the statement is true in part or as to some items, but not true in full or as to all items, then answer
separately as to each part or item.
b. If you have been sued in more than one capacity or if your answers would be
different if answered in any different capacity, such as partner, agent, corporate officer or director
or the like, then you are requested to answer separately in each such capacity. Failure to do so
constitutes an admission in any such capacity.
..X
C
In these Requests for Admissions:
A. The word "person(s)" means all entities, and, without limiting the
generality of the foregoing, includes natural persons, joint owners, associations, companies,
partnerships, joint ventures, trusts, and estates;
B. Tile word "documen4s)" m:.ans all ,,,ritten, printed, recorded, graphic, or
photographic matter, ^T. 501iild rCDrodijCL7
manner to the subject matter indicated;
C. The words "identity" "identify "identification", when used with
respect to a person(s) means to state the full name and present or last known address and business
address of such person(s) and, if an actual person, his present or last known job title, and the
name and address of his present or last known employers;
D. The words "identity "identify" "identification", when used with respect
to a date, subject matter, name(s) or person(s) that wrote, signed initialed, dictated or otherwise
participated in the creation of the same, the name(s) of the addressee or addressees if any and the
name(s) and address(es) of each person who have possession, custody, and control of said
document(s). If any such document was, but is no longer in your possession, custody, or control,
or in existence, state the date and manner of its disposition; and
E. The word "identi ', when used with respect to an act (including an
alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act"), means
to (1) describe the substance of the event or events constituting such an act, and to state the date
when such act occurred; (2) identify each and every person(s) participating in such an act; (3)
identify all other person(s) (if any) present when such act occurred; (4) state whether any minutes,
notes, memoranda, or other record of such act was made; (5) state whether such record now
exists; and (6) identify the person(s) presently having possession, custody or control of such
record.
8. Unless otherwise indicated, all Requests herein relate to those pertain events,
persons, and period of time more fully described in the pleading in this case-
9. These requests are of a continuous nature.
These Requests for Production of Documents shall be deemed continuing so as to require
supplemental answers and documents if any information of documents are acquired subsequent to
the filing of responses hereto, which information or documents would have been included in the
answers and documents produced had it been known or available at the time the answers and the
documents provided pursuant hereto were produced. Defendants shall supply such information
and documents by supplemental answers and production of documents as soon as such
information becomes known or available and in all events, prior to trial of this action.
If objection is made to any requests for production of documents, it is demanded that the
requests for which there is no objection be answered and furnished within the aforesaid period.
All documents identified in response hereto shall be organized and labeled to correspond
with the request to which it pertains. For all documents produced, list the individual and his or
her job title and department from whose files it was produced and the current custodian of said
document.
If a document called for is believed to exist or is known to exist, but is in the possession,
custody or control of another person or party, the existence of the document, the identity of the
possessor, custodian and one in control of such documents shall be provided along with any
applicable common description or citation utilized by the publisher, possessor, custodian or
disseminator of such document.
iL anV document .;alied .Jr IT "i, " S -./ rlhtjd ?,n •_i.? bads )i any claim of
priviiege or any similar claim, identify that doc?_lmcnt as yellows: author; addressee; indicated or
blind copies, date, subject matter; number of pages; attachments or appendices; all persons to
whom distributed, shown or explained; present custodian; and nature of the privilege or similar
claim asserted.
REQUEST FOR PRODUCTION OF DOCUMENTS 1:
Produce any and all documents evidencing proof of all payments on the subject credit
card referenced in the Complaint, including, but not limited to, cancelled checks, receipts,
coupons, statements, accountings, memoranda, invoices, financial statements, accounting entries,
diaries, charts, lists, phone records, data compilations etc.
REQUEST FOR PRODUCTION OF DOCUMENTS 2:
Produce any and all documents you intend to introduce and/or provide testimony on as
evidence at the time of trial.
REQUEST FOR PRODUCTION OF DOCUMENTS 3:
Produce all documentary evidence or information substantiating the defenses asserted in
your Answer.
REQUEST FOR ADMISSION NO. 1:
Listed as Exhibit "I", Defendant signed the credit card application referenced in the Plaintiff's
C- 01T10 a{ nt.
Admitted
Denied
If the answer to Request for Admissions No. I is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 2:_
Defendant received and used the credit card referenced in the underlying action.
Admitted
Denied
If the answer to Request for Admissions No. 2 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 3:
Defendant resides at the address listed on the monthly Statements dated October 12, 2009 through
tilay 12, 2010 and attached to these requests as
Admitted
Denied
If the answer to Request for Admissions No.3 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request
and identify the Defendant's addresses and the dates that Defendant resided at the said address.
REQUEST FOR ADMISSION NO.4
The purchases and/or balance transfers and/or cash advances listed on the monthly statements
attached hereto as Exhibit "2" are correctly identified for the underlying credit account.
Admitted
Denied
If the answer to Request for Admissions No. 4 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 5:
The payments and/or credits listed within the monthly statements attached hereto as Exhibit "2"
are correctly identified for the underlyiniz credit account.
Admitted
Denied
If the answer to Request for Admissions No. 5 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 6:
Defendant made no payment on the credit card since November 01, 2009.
Adm itted
Denied
If the answer to Request for Admissions No. 6 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied-
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 7:
The credit card account which is the subject of the underlying action accrued interest at a variable
rate.
A dm fitted
Denied
If the answer to Request for Admissions No. 7 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 8:
The interest rates listed within the monthly statements attached hereto as Exhibit "2" correctly
identify the interest rates for the underlying credit account.
Admitted
Denied
If the answer to Request for Admissions No. 8 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 9:
Defendant has not submitted any written dispute as to billing inaccuracy concerning the credit
:,sad ;n f,+_iestion.
"'j"11 ;C{ "C!
Denied
if the answer to Request for Admissions No. 9 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
REQUEST FOR ADMISSION NO. 10:
$9,892.70 is a correct and accurate current balance of the credit card account in question as of
>?ntem;?e S. 010.
Denied
If the answer to Request for Admissions No. 10 is anything other than an unqualified admission,
please qualify your response by setting forth which parts of the request are admitted and which
parts are denied, or set forth in detail the reasons why the answer cannot be admitted or denied.
Please attach any documentation in your possession that supports your response to this request.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
William T. Mol n, Esquire
Pa. I.D. 94743
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR:8467943
DEFENDANT'S VERIFICATION
I_ _, (please print) under penalty of perjury and
tnz penalties')r 13 Pa.C.S. Scctlotl 1904 ielitlmz to
117arity that the foregoing Responses are true and correct to the hest of m,,, ??.r(edge, information
and belief.
Date
Signature
CERTIFICATE OF SERVICE
A true and correct copy of Plaintiff's First Request for Production of Documents and
Request for Admissions has been served by U.S. Mail, on the day of
Cc ?i t;v, 1 1 nu
Marcus McKnight, Esquire
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013
BY: k?z? j'woe??
CO! Send my ( - = - - 1
no-annual-fee Visa 1 =*
Platinum card 6 _ I!
Place sticker I
here Bow--
If you do not check a box, you will -
receive the Moonstone Visa Platinum card.
Choose your card color.
19 ? Ocean elue i 22 f fluty Fled
- _>?J (? .`-oiest t;r=en ' ?3 ? Tnwz `.?eeow
-I j Moonstona Gmy
Please correct infomatim bellow if necessary.
Shirley Amold
263 Icings Hwy.
Landing, NJ 07850-1060
939-76631-0529-5
1939NB
November 21 2002
IMPo1TrANT: To avoid delays, please complete all requested Information below.
___7&55 a I Employment
Social Security Number
$ 00
tAnnual Hou ncome
(M) 6 91- 7yo9
U.S. Home Phone
Work/Second Phone
Do you have a chedang aaalnt? Yes 0 Uo
Residential Status El Rent Own 0 Other
went ernp!Wer?
How have you cu
Month(s)
How many times in the past 6 months have you
Iklen a cash advance from any of your credit cards?
o ? '--3 -Ij 3+
Do you plan}rr ase ills card to get cash at an ATM?
? Yes No ? Maybe
Signature G ??-O`I'
This form is non-kansferabow must be signed by lllQ persarff/ it is c Z hat I are at least IS years
of age. I have read and agree to the Terms and Con?tirms on the back of the leaer a he Initial Disclosures.
?You do nd need to tecklde bcerne trap *NM, chN support, or separate a m*ss youvmrdd file m to consider t
VISA PLATINUM BALANCE TRANSFER REQUEST
YES! I want to transfer the following balance(s) from my higher late accounts to the Visa Platinum card. And there's no balance transfer fee!
I want the balance(s) transferred immediately, therefore, I agree to review Providan's Privacy Policy later along with other account information.
O
Account Number
cAPf-rAL a??
Name of Credit Card Lender
$ 500 .00
Amount to Be Paid and Transferred
(minimum $100)
9 /-,939,5f
Account Number
?AO/TAG Of&
Name of Credit-Card Lender
$ 300.00
Amount to Be Paid and Transferred
(minimum ¢100)
I] Self-Employed O mpbyed
? Retired f.11fth ther
Year(sAccount Number
Name of Credit Card Lender
Amount to He Paid and Transferred
(minimum $300)
.00
RAO1776
939-76631-0529-5
8467943
Payment Due Dwe New Balance Pass Due Amount MlNmum Payment
77!05/09 -68.564 20 -6221 tXl -6514.00
Account 111um1oer: 4185 5060 0210 1215
. Make yourcheck p.yable to:
Chase Cxd 9erviees.
Ple.s. write amount enclosed
New address x e mail Pnnt on bed(
4]855360021012150005140000856420000000000000004
, IR.SEX= Y ARNOL
,
-42 PHEASSANT OR O
t 142 PR N
CAFLtSLE PA 1707)-1251
1: 5000L60281: L99600210L2LS L5a
CARDMEMBER SERVUE
FO BOX 15153
WILMINGTON DE 19886-5153
FXHIBp
Slatamml Date
CHASE O 09/13/79-10/12/09 hYmgeye+r.ccourhton6x
www chase mnYOedicards
Whim- Pay-11 -6514.00
Payment Due Date. 11106/09
8467943
Addid-d Com.Q kdormh.N4n
ACCOUNT SUMMARY Aecounlhlumber: 41,95 5080 0210 1215 con-m-tyI-Mad on-r- sid,,
Prawous Balance $8.79448 Total Credo Line $0.500
Paym-1 Credits -$43800 Avaiable, Credil $0
Purchases. Cash. Debts .$38.00 Cash Access Line $1700
Finance Charges 0/5168 72 Avaiaole for Cash $0
N- 2-,- $8.56420
important Message Over Ced,t Limit
Your 5tatam- I balance exceeds your credit bmt You should make a paymen11hal includes the ov rlmwl amount and brings the
balance under your liml
ACCOUNT ACT[V(rY
Dale of
Transecton M-cnanl Name or Transacion Desaolion $Arounl
07/19 CARE COM INC 781-6425900 MA -25.00
06/19 CARE COM INC 781-64259011 MA -25 00
09124 Payment - Thank You -31 fi 00
09/24 Late Fee Reversal -39 00
09/24 OwMairt Fee Reversal -39 00
70/07 LATE FEE 39 00
FINANCE CHARGES
Fnance Charge Tcarsacao,
Daffy Penoo,r Rate Cc--,_. Averaa?',,Ady Due To F- ACcurnufaled FINANCE
Category 30 days in cycle ?"R :e Perecic Rate Service Chwo,e Fn Charge CHARGES
Purcnases V (Wi41% 1%. st7 '9 $16B. 72 S3 t 0 -60.00 $168 72
C-h Adyances v - 1141-1. :....1•%. t. "n ro 00 E) ..-..: $0 00 $000
Total finance charges $168 72
Effective Annual Percentage Rale (APP.) 24.24%
Please see IMormahon Aboul Yew At, -, ge ion for hAlenre computation method, grace per J. and other important ,nlormalion
Th., Corresponding APR is the rale of ,merest yr a pay 11- you carry a balance, on my
The Flleaive APR r.presents your oral inane Chao)- . , -luding transaction fees
such as r'2Sh advance anC ha'm,oe transler tees - 5r:-??-d as a perCCnlaoe
This Statement Is a Facsimile - Not an original
OGQx01 F,5311t.D 12 eG'J N Z 12 1-.-- Pahl dl 05686 ---Q
2aS1OW0120aVh x8)1101
X
2of25
Payment Due Date New Balance Past Due Arnounl Minimum Payment
12!07!09 $B-477.82 $215 00 551200
Accouryl rwmber: 4185 5060 02101215
. Make your chcok payable to.
Ch- Card 9aeldeea.
Floe"-de amgnt enclosed
New address or emei' Pnnt on baW
4165S0600210121S0005120000847792000000000000004
-?HiRI tY AR NOLD
2 PHFASANi C R N CARDMEMBER SERVk:E
.ARLISLE PA 170113-1251 PO BOX 15153
WILMINGTON DE 19086-5153
is 5000 16? 28a: L99600 2 10 &2;6S Lill
Statement Date
CHASE O 10/13108 -11112/00
tdanagr ywe aaeurr[ oMine:
wYYW chase mrtVacdicards
MEnimtrrt Payment. $512.00
Pay-1 Due Data 12107me
Addidm.1 -tact irdon-tion
ACCOUNT SUMMARY A....1 Nu.*. 4185 5060 0210 121 5 mmerrendyiocraedmrnversesde
Previous Balance $8,564.20 Total Credit tine $0,500
Payment, Credns -$299.00 Available Credit $22
P-has"'. Cash. Debts 1$38.00 Cash Access Line $1,700
Finance Charges 4173.72 Avaiahie for Cash $o
Nov Brdanrv $8.47792
ACCOUNT ACTIVITY
Dale of
Transaction Merchenl Name or Transaction Descrotan $ Aiirouni
11/01 Payment - Thank You -221 00
1D/D7 LATE FEE REVERSAL -3900
09106 LATE FEE REVERSAL -39 DO
11/06 LATE FEE 39.00
FINANCE CHARGES
Finance Charge Transaction
Cady Penodc ?, rte Corresp Average Daily Due To Feel AcwnxAaled FINANCE
Category 31 days in yde APR Balance Periodic Rate Service Charge Fin Charge C' ARGES
P,,,-,-- V 06^41% 2424% $0.43843 $173.72 $000 $000
r,". advances V.06541% 24.24% $D OD $0.00 $000 $0.00
=! I,nance charges
.dive Annual Percentage Rate (APR): 21.24%
Inlonnation AI-I Yr- Acco<im seclion for ::- lance compulalion nteih? : ,.;raceperiod and other-prowl into-Ia!,on
orr?sponding APRs the rte of inlerest you pay Mien you carry a balance or :.ny irnsactinn category
+.e Ell-i- APR repra-l,, , v total finance chwgev - mduding lransectlon lees
such as casts advance anc --ice Iransfer lees - ea[_*r-wed as a percenlage
(IMPORTANT NEWS I
ChP.P Gill Cards, The Perlecl G, I
Avadatl, any arnounl tom $251:_ boo
Acceplee nvlinrls of localions woh-1M,fe
Order on+.- at ch.- corri/G.IIC-10,d,
or stop by a Chase Branch loday,
8467943
This Statement is a Facsimile - Not an original
-in-rat FF3lJaeD 12 dea N Z 12 0A-2 Pau., d' is's,
1\ '?"43W
4of2S
Payment Due Date New Balance Past Due Amount Minimum Payment
01/06110 $0,68762 $572.00 $80400
AccoulA number: 4185 5060 0210 1215
. hate ye wchecMpayeblete:
Chase Caro Services-
Pl-wrde amornt enelos d
New eddnlss or -.0 Prim rxr ood+
418550600210121?-0008080000868762000000000000006
31IRL=Y ARM,' 0
' 142 PHEASAW ID V N
,ARLISLE PA 170:3-1251
1: 5000 LGO 281: L996002 iO 12 L5 Lae
Addieenal oerrb t Intemrllen
ACCOUNT SUMMARY Account Number 4105 5090 0210 121Sconvenimly located on reverse tide
Previoas Balance $0.47792 Total Credit Line $8,500
Purchases. Cash. Oettits X539.00 Avadable Credil $0
Finance Charges .$170.70 Cash Access Line $1 700
New Balance $8,607 62 Avala6le for Cash $0
Slatentent Date:
CHASE O 11/13/09-12/12109
Menge your aasouru online:
wa'M [haSP.COrrMCIPda[Yd3
Minknlan Payment. 5808.00
Payment Due Dale: 01106/10
8467943
Your credit card account is past due Pease send paymentmmedlately Call 1-800-955-8030 (codecl 1-302-594-8200) today
JACCOUNT ACTIVrTY
Date of
Trdnsaclon Merchant Name or Transaction Description Amounl
12/07 LATE FEE 39 00
FINANCE CHARGES
Finance Charge TransacEOn
Deily Periolchcka?- I-esp. Average Daily Due To Feel Accumulated '1NANCE
Category 30 daysin lyde APR Balance Periodic Rate S"ce Charge Fn Charge CHARGES
Purchases V 06641% 24.24% $8,56796 $170.70 $000 $000 3'. 10
Cash advr,n:e s V 18641% 24 24% S0.00 $000 $000 70 00 b.: 00
7o1aI Lnan o.? harg es
CAROMEMBER SERVICE
PO BOX 15153
WILMINGTON DE 19886-5153
51 %0 70
Etleetlve Annual Pers.--roe Rate (APR): 24.249E
Please 5=-. nlon , allon -;..o! Your A-111 secflon for balance computation method, grace perico. and 0lP. sIpotlaot IN-I'lon
The Cora.. , -1:••g AP" ine rale M interest you pay whm you carry a balance on any lrarsacr,. l category
The E11-.- , A:--7:eF.?xn;s your u.tal lnaree cha gas - /lauding transaction lees
such a:: rd , 9 ]vancc a :valance l,ansla fees - expressed as a percentage
This Statement is a Facsimile - Not an original
OOCO001 P6i3SlC C 090 M Z 1z 0w1]n2 Page 1 p' 'J'%tb W 4A Saa56 3x51 U•,- +,?_,J53a56?n
R
6 oi25
Payment Due Date New Bad wee Past Due Amount Mlnlmum Payment
02/08!10 $e-94726 $80800 $1,118.00
Aceow" number 4185 5060 0210 1215
Make your chagf payable to:
Chase Card 9arvieea.
Pkasa wrrta artUkall enCiosad
New address a, -.0 Print cur beck
11855061;O210121530111800008947260017000000000002
-.sae -11<.D I...
3F.IRL.'f ARNOLD
142 P11 EASANT CR N CAROMEMBER SERVICE
JARLISLE PA 17013- 1251 PO BOX 15153
WILMINGTON DE 19886-5153
1:5000 L60 281: L99600 2 10 12 15 L11a
Statement Dale
CHASE 12/13/09 - 01112/10 Manage ywa aaount Online:
wYMw Chase 9Q1W l?ddcards
lmnirna Payment: $1,118.00
Payment Due Dab' 02105110
AddiGrnal Conba Ir.fornr --
ACCOUNT SUMMARY Account Number. 41 85 5060 0210 121 acn-m-ily lxated On reverse 9de
Pre us Balance 58.687.62 TOlal Credo Line $8.500
Purdlases. Cash, Debits +$7800 Available Credit $0
r,nance Charges 1$181 54 Cash Access Line $1,700
New Balance $8.94726 At tgble/or Cash $0
The charge prmleges on your vecu card account have been revoked you no "Or have the ability 10 use your credil card
account for purchases. We can help you gel back on Tack. Call 1-800-955-8030 (coltecl 1-302-594-8200) 10d ay
ACCOUNT ACTIVITY
Date of
Transecnon Merchenl Nsme or -Iran Arnouni
C 1106 LATE FEE 3900
12/73 OVER LIMIT FEF 3900
FINANCE CHARGES _
R.:afnr ?. aroe Transacbon
Daly Periodic L ale Corresp Avau- q Daily T_:L9 To Fee! Accumulated FINANCE
CelegOry 31 oaystn cycle APR Balance c Bale Service Charge Fin Charge CHARGES
Purchases V 05541: 24.24% __52293 ..`_5a $0 C _ $0.00 $18164
Cash advances V 06541% 24 24% SO % 00 $O.c ,
$0 00
$0.00
Total finance ctlarges
$181 64
Effective Annual Percenlaq< Rate (APR)s 24._1%
Please sea Ini-ahon Aboui "Dur Account seafon for t,? : -e ?:ompulallon rnalhod- grace period. z '- er im: • ,; tnfc•-nation.
The Corresponding APR i, a e ._ f inleresi you pay when you carry a balance on any transaclion net -_ pry
The Effective APR repre?^.. ? +rnal firlance rhar0•-: ?nCud?ng lransaclion tees
such as cash advance ane •?. transfer I-, - - -s p.d as a percrnlage
IMPORTANT NEWS
try h,-Tax Free Edroon Mr . -- simple relurn
.::•?1 a 35 pwcwi Gs,,ird on
Online Federal `',4t cts
vsi chasecorNlares
8467943
This Statement Is a Facsimile - Not an original
eu 01 Fr-33 .0 000 . Z 12 - Pier1 a1 Oleea Mn Yq •. 0:2f addef2006"' 19901
z
8 of 25
Payment Due Date New Balance Past Due Amount Minimum Payment
OOI09/10 $9.21227 57,11800 (1,436-00
Account number: 4185 5080 0210 1215
make dhek Payable to,
Chao Card 9avfw.
Please vrito amountw iosed
New address or enter Pmt on beck
°11855060021012150014360000421227000000000000002
-?-s sok ? kw.o 0
=+IRL? Y.4RNOL0
12 PEASANT C R N
; RLISLE PA 17013-1251
l...I11r.rlH.moil..Il....ILrLLLi....Ii.1..LrirLrlLl
CAROMEMBER SERVICE
PO BOX 15153
''WILMINGTON DE 18886-5153
1:5000 L60 28s: 1,99600 2 10 L 2 l5 Lira
CHASE O JP .-g1`, your aeoourd -11- Additional contact Information
www chase mmcreditcards cmwniensY loealod on rovarso siao
8467943
ACCOUNT SUMMARY
Account Number 41855060 02101215
Previous Balance $8.94725
Feas Charged +$78-00
Interest Charges •$18701
New Balan- $0.21227
Opernng,iClosing Date 01/13110 - 02112/10
Total Cretin Line $6,500
Averted,, Credit $0
Cash Access Line $1700
Availade for Cash SO
PAYMENT INFORMATION
New Balance $9,212-27
Payment Due Date 03/09/10
h5nmum P8yment Due $1.436.00
Late Payment Warning If we do not receive your minimum
payment by the date listed above, you may have 10 pay up to a
539.00 late tee and your APRs will be sutlect to increase to a
rmxirnm Penalty APR of 29 99%
.
Minimum Payment Warning: 11 you make only the rrrimrnrn
payment each period. you will pay more in trilwest and it will take
you longer to pay off your balance For example.
It you make no You wig pay oft And you vNl end up
ad6eonal charges the balance paying an eslirlreled total
using this card and shown on this of
each month you staternertt in
pay about
Only the rtxrlimum 33 years $27.45100
1,.Y K 11
5354 00 3 years 513.09500
(Savings=$14,356 00)
H yak. .old like Inicradon about credit counseling services- raj;
1-866-797-2885
ou haven` --' f?19 4nr : equ,red payments and your credit card accounl is b0 days post due Asa resth, your credo bureau may t»
updated win, :- : -caiive clung. Please send your payment inrnechaiely or call us at 1-800-955-8030 (cWleci i-302-594-820(,) , NY
'mporlant Mr,-,,ge_ You Are Ovedlrtu-
Your statem -", -.alance exceeds your credit line Yon - ,uld make a payment chat ;nc ludes the Owwimn amount to bring 1n+
balanco kn, :, your v do Ina
ACCOUNT ACTIVITY
Da a ^i
'ran..«.. r. ?srchant Name or T, n-s lion Dev.nption S f•.mkwnt
?FFESO4AAGED:
.....................
(12!07 LATE I F 39 raj
-113 OVER'. 1:T FEE -9 no
TOTAL FEES FOR TH,:; PERIOD S78 o0
:tNXt3tK5L:Ct1#NSiCdED:
.............. .................
02712 PURCHASE *INTEREST CHARGE' 11`701
TOTAL;- ' :-REST FOR THIS PERIOD < 19 7 Q I
2DtDTlaaficYllpyp?Dartr.
Total tees charged in 20:0 $7000
Total imareal charged in :?, 10 $187.01
Yea-to-dale totai< res all charges min is nny refun?s
applied to year ,.:--i x or aher January 31 201 z.
This Statement is a Facsimile - Not an original
ooaoao. cs:•:.w.os me r. - .•;,mnz Paeet a: os.:b --Ms
DrJt o0o0o5oeorZr em
,rrsh..aa
10 of 25
Sialemenl bale 01113110 - 02112/10
Asoum Number 4185 5060 0210 1215
Page 2 of 2
8467943
JINTEREST CHARGES
Your Annual Percentage Rate (APR) is the amual interest ale an your acwunt
Annual Balance Acaued
9a1ance Percentage Rat*(APR) Subject T. Itnereat Interest
Type 31 Days In Cycle Intuest Rate Charges Charges
.'•,rr.^.ases 4Y.(:) Uoa391 118701 $000
'asn Ad--- . 24o,,) so 00 $o 00 $o 0o
- Va-o, Rare
Wease sae ht-w,cn Abeul Your Account seClon for the Calculation of Balance Suttecl 10 Inleresl Rav Annual Renewel Notice
I-bw 10 Avoid m±eresl on Purchases, and other -ponant inlormstion, as applicable
This Statement Is a Facsimile - Not an original
R omooo, cis:: @Os - N L -M12 I.C.2- oseee .u ..r, xzo+e ora+ocoxsooo,zwtloz
12 of 25
Payment Due Date New Balance Pa51 Due Amount Minimum Payment
04!09!10 $9,42422 $143600 57,74200
Account nolmber- 4185 5060 0210 1215
. Make y- Check payableto:
Chase Cvd S-i-
$1 amount .-I..d
New address or -AI Print on 6noc
418S50600210121500174e00009424e2000000000000002
3i-11RLEY AR HOLD
I 142 PHEASANT DR Y CAROMEMBE.4 SERVICE
r. ARLISLE PA 17,013-1251 PO BOX 15153
WILMINGTON DE 19886-5153
1..rtll.rd0..a...ILrll.,.ril.rLl,LLr..11.1..L.Ll.rllrl
1:5000 L60 281: L99600 2 LO L 2 15 10
CHASE L? M.n.ge your ae-m mane: Additfond wnraa Ir/urmation
www chase com1creditcantis canvenipndy located on r-w slier
ACCOUNT SUMMARY
Aocoun/Nurnber 4105 5060 021 0 1 215
Previous Be-- $9.212 27
Fees Charged S3900
Interest Charged S17295
New Balance $0.424.22
Opefing)Closing Date 02/13110 - 03112110
Total Credit Line $8.500
A-latie Credit $D
Cash Access Lirle $1,700
Available for Cash $0
PAYMENT INFORMATION
New Balance $9,424.22
Payment Dun Date 04A9110
Minimum Payment Due $1 742.00
Late Payment Warning If we do not receive your mini um
payment by the date listed above. you may have 10 pay up to a
$39 00 late lee and your APRs will be subject to increase to a
maximum Penalty APR of 29 99%
Minimum Payment Warning: It you make only the rnrtimum
payment each period, you will pay more in interest and it wig lake
you longer to pay 0 your balance For eranple.
It you make no You will pay ott me And you -11 end up
additional charges balance snow,'. n paying an estimated
usng IN, card and 1M5 slalerner:: ?I total of
each mc•nih you about
pay
.
Only lhn minimum .
33 Y••, $28.100
payment
£372 3yec $13396
(SavMs-$14.704)
It yc,: would like inlo.matron abo.. -.=din counseling services, reli
i °e6-797-2885
ITS ??c•1 too later io resdvF e? outstand?n?? t•:,lanoe en your aedd ca• ; armtnt. 009 ?-tee a vanely -.+;,:»vmerrt opuore that mar be
r?,?h!!or ynu Call 1-888- •"S[7(-Leal i-302-594-82001 today
Imp nianl u--.-age Yo, 0-1-9
Your stave, . I balance -• :. ds your credit hne You should make a pny,`rtnt /ha; inc'udes The r v arlrc-nil amount to brim --:•
balance lA...:w Jow C!Y; :.?• _
ACCOUNT ACTIVITY
Date of
I renaacticil Merchem Name or Transaction Descnpi,on ?.
......................
FEESCt1ARG£D:
D3/09 -ATE FEE
TOTAL FF -S FOR THIS PERIOD r„-
IN- I..... S iAkdEb
33"2 PURCHASE INTEREST CHAR(
TOTAL INTEREST' : r: THI; PERIOD
MID
7aiais:Yeat'?o-Osle:
-
Total fees charged i.: 2010 $11700
Total interest a
,, _> J in 2010 $35996
i
Year-to-dale ic'!.a:c reile;i all charges minus tii ry refunds
appked to your account ai nr aler .lama: y _ 1 2010.
8467943
This Statement is a Facsimile - Not an original
IX•rOnet Fi..311Y±D t2 20 v z t? .::.^tn; Paper tl2 a56P6 rn.n MA ZS25 0711 ctiM'?:•:?_eu5or
14 of 25
Sialemenl Date 02113/10 - 03/12110
Amount Nu Yb- 4105 5060 0210 1215
Page 2 012
INTEREST CHARGES
Your Annual Percentage Rate (APR)is the annual iraeresl rate on your account.
Annual Balance A-ued
Balance Percentage Rate (APR) Subject To Interest Irrlereat
Type 29 Days to Cyde interest .gate Charges Charges
ou.-Charms ? 4.14Y. (v) ?a 300 x.12 5112 95 S000
Cash AC--- ?'4. 24%rv) s3 s0 s0.uo $000
= V.-He Rate
Please see hbrMH11M About Your Account section for the C4mlation of Balance SLOect to Interest Rate, Annul Renewal Nol-
I+ow 10 Awb Interest on Piscllases, and other imponant inlownatlon, as appheable
8467943
This Statement Is a Facsimile - Not an ario_ Ina!
X OOCe001 FSalTfap i.' = N L 12 -"12 P.W: --"2-326M2
16 c`: 25
Payment Due Date New BAance Past Due Amount MlN mtm Payment
05!08710 59,659 29 S7 742.00 52,073.00
Account t7umber: 4185 5060 0270 1215
. Make your beck Payable to:
Char card S-1-
$1 wrav arrount onctosed
New address or -.41 Prof on bads
4l8j5O6Oug2?oi215aa2D73o0170°,65929cODDt]L°000O00Do7
I z R oo i...lILL.L.LL.l..il...1.i....i1,i.1...N..td...11..ii..i
? Y
iFtiIRLE RLE
ARHOLD
1142 PH EO>ANT CR N :.'ARCMEM9ER SERVICE
CARLISLE PA 17013-1251 PO BOX 15153
WILMINGTON DE 19866-5153
,:S000160281: L99600 2 10 L 2 L 5 Laa
CHASE O hYnage year aeeaunt adN e: Addid-al -nI i.de Iiiin
www Chase conNeradteards canvaniandy focatttd on reverse ed.
8467943
ACCOUNT SUMMARY
Atta 1 Number 418S 5060 02101215
Previous Balance $9,424 22
Fees Charged ,$39.00
Interest Charged .$106.07
New Balance $0,659.29
Openng/C"ng Date 03/12110 - 04112110
Total Credo line $0.500
Avadabie Credn $0
Cash Act Line $1,700
Available for Cash $o
PAYMENT INFORMATION
New Balance $9.65929
Payment Due Date 05/79/10
Mrnmum Payment Due S207300
Late Payment Warning II we do not receive your minimum
payment byte the sate listed above, you may have 10 pay up to a
539 00 la lee and your APRs wit be wgect to increase to a
maximum Penalty APR of 29 99%
Minimum Payment Warning: It you make only the minimum
payment each period. you will pay more in interest and it wig take
you longer to pay Of your balance For example.
It you make no You wan pay oft the And you volt end up
addnionel charges balance shown on paying an estinreied
using th!s card and this statement in Iola! of
each month you about.
Pay
Only the mrnrnum 33 years $26 766
PaYrr i
$3al 3years St:,7_-1
(Savings.- S I ; X36)
you -lo like,Mormaaon about credit coursMirul sern? • rail
You have - "ace the required peymenls arn- r -tI car: - - ::ount 5 150 days past clue. You can still turn lhmgs around Cap
us today al ', -066-792-7547 (aJlecl 1-302-55-' ..i _; va that pan hind a soluunn for your silLation.
Imponanl Message- You Are Overfhnxl!
Your stalenwn balance exoeeds your credit Gn YO--should
balance -1- your credit line
ACCOUNT ACTIVITY _
Date of
Transaction Merchant Name i,r -trnsacthon Desc,ipAort
$ A(Tx., ,l
......... .............
FE£SOffiAGED
04/09 LATE FEE :p 00
-.ALFE? ?.,-HISPC !:900
?1NI'.EttE_? *:EifAAf2EC}
04112 PURCHASE INTEREST CiT ..RGE 19607
Tr,TAL INTEREST FOR THIS PERIOD S19107
20f>y_i'alal Ynhro{o:?;a- .
Total lees charged in 2C $156.00
Total interest charged in i $556.03
Year4o-dale totals rely-; a-J charges minus any refunds
applied <. your . •? or atler January 31 2010.
This Statement Is a Facsimile - NF,+ an original
X
ODCWD1 F15,11'i'ia Da Oe0 4 Z 12 16err1' .ere tretib ,.tn .r.+nn5ee h?i000-gfiCO:.,J6.a0i
IS of 25
Slalemenl Cate 03/13710 - W12110
Account Number 4185 5060 0210 1215
Page 2 of 2
INTEREST CHARGES _
Your Annual Percentage Rate (APR) is the annual Inleesf rate on your aceouni
Annual Balance A-ued
Balance Pe_nUge Rate (APR) 9ubjxl T. Inleres7 Inlereat
Type rt nays In Cyde tntdest Rate Charges Charges
?.?-h-, 24 24!t. ;0.523 I'd b' 35 n $000
1--.1 .+nvances 24 24-,- so cc GJ.00 $0 00
(V) .Van ary9 7e1P.
Please see iMormalton Aboul Your Acwunt sectton br the CaloAauen of Balance Sugec to Irieresi Sate Annual Renewal Noii,
H;w to A- j ktleresl on Purbteses. and otter imporlanl Irdorm8lion. as applicable
8467943
This Statement Is a Facsimile - Not an original
)( 0o(:Orr:. :_ ".-'`.9 00D M Z t2 1-12 I.Q. i 05866 r.N NN 60Y{ 1MWW1)eW116CbH02
20 of 25
Payment Due Date New Balance Pori Due Amount Minimum Parrntim
06410110 59,892.70 52.073.110 52,005,00
Accourit ntanber 4185 5080 0210 7215
$ Ch- Card 9ervkes.
Plras erlocnt end0sad.
ed
r`1a- .6d tddness m PTetl? I'nn1 M bed.
41855060021012150024050000989270000000000000003
Set1eteaz 01-
SHIRR AR 401-0 !...1111 1..1..7.i..i..11...i.i....
.
1142 PHEASANT DR N CARLISLE PA 17013_1251 PO O BOX X 15153
SERVICE
PO
15 t53
WILMINGTON DE 19ea6-5153
1-ill... III...... 111.111 ... JI I 1....I Id..L.LL.I I I
1: 5000 1,60 28f: 199 600 2 10 1 2 1 5 tat
CHASE O B Yae.gt your acwunl wine:
Aderbnd rsr.hQ Hemwtfow
ksMa!-fftal9-?j1?LLL1 can tvilly lowbd on -. ida
ACCOUNT SUMMARY
Account Nurr.btr: 4195 5060 02101215
Pramous Balance $0.659.29
Fees Charged +539.00
Interest Charged aS14141
New Balance $9,092.70
OpeningJClosing Date 04113110 - 05112110
Total Credit Lino S8.500
Available Credit So
Cash Maas Lim S1300
Available for Cash 5o
PAYMENT INFORMATION
New Balance SB,tl92-70
Peymera Due Der. 06/39110
1ArVMM Payi nien Due $2.405.00
1-21e Payment Warning: It we do not ceoaive your minimum
Ptymem by the dab fisted dove, you Tey have 10 pay up 10 a
S39 00 laaa tae and your APRs will be sut iao to in,,r"w 10 a
ntBSma+n Penally APA of 29.99X.
Mnlnunt Ptynm" Warning: if you make only the ntrinaan
paymem each period. you will pay mue in irnareat and it will take
you longer to pay o8 your halana For erarri
It you make m You wig pay oft the And you wta and up
additional charges balance shown on paling an estimated
using this cud and this statement in total of...
each Tenth you about..
Pay-..
Only Vie nantrMun
Payment 34 Was 529,506
f39/ 3 years S1 4,062
(Savngs.E15 44411
A you Would tike irdormeaon about credit counswim, servicee- Ceti
i-966797-2905.
The Outstanding telanoe G_ ,; "calm czzd acoarnt a scheduled to be wdnen off nil a bad debt shortly" As a resit, your credt
bureau wig be m,.riatad win -?..oatne ratr
in0 that could last for up to seven years. We car. sail heiR but you need m ®1 rye now a1
1-889-792-75? ' z11e 5s4-82001.
Irnpnn IM Mesvsgc: Y- Arc (',, dlrritl
Your tatmnerht oNanw eza.rr¢ your credit line. You shr;utd make a payrnem that intludas ate w..r nrt amour; -u briny fie
balerha under yns aedrt line -
ACCOUNT ACTIVITY -
Dare of - ----?
Transactor,
Mereham Nane or Tranaaefon DI
f
sctp
on S Amount
...
_.:-:
-
- :
..,-. .
--------------- -
OY09 .
...::". .... .-
1..4TE FEE ... .< .. .....=:.`-.
39 00
TOTAL FEES FOR THIS PERIOD
--- ----------- L39.00
---
05/72 PURCHASE INTERESTCNARGE - - "- ...-
- "
05/72
PUfiCHASF INTEREST CHARGE 70
794 31
TOTAL INTEREST FOR THIS PERIOD
St9441
Nt-3:;: x;: _=::2dt>k:pl'?R'Si11f01itritll8t^ v .
Total feeschargedin 2010 519500 I
Total interest Charged in 2010 $ jSO 44 t(
ear-to eta totals reBect all charges, Minus any refunds
applied to your account on or affair Jamary 31, 2010 -
INTEREST CHARGES
Your Annual Pe.cwnage Rat. (APfp is the annual imI, ?t rate on your acmtnt.
Amid Berm.-
Battnes P.. ,_too. Raft (APR) Subject ..o I Acoued
nterest
8467943 Type Days In Cycle inbrset R- Char g"
gse
Purchases
(111 $9,75285 5194
31 Charges
.
PurClesss 24.24X (Y) 55
20 50.00
.
solo $0 00
This Statement Is a Facsimile - Not an original
ODm00t Fi
'
gh31
fr 013 000 N 2 12 1 2 Pge1 O2 Owes
7{ tow. sn 7e .
32, aoo013am?n lea
2 of 5
Stalernem Dale_ 04/17/10-05/12/10
Aecourn Number: 4105 5066 0210 1215
Page 2 of 2
INTEREST CHARGES CONTINUED
Your Annual Percentage Rate (APR)is fie annual interest rare on your account.
Annual Balance Acouea
Balance Percenage Rate (APR) Subject To Irrh"*t interest
TyP'+ 30 Cat's In Cyde idteroel Rate Charges Charges
Cash Advances 24.24Y. NI so to 50.00 50
00
Cash Advances ?4.24%(v! so on woo .
$0.00
(v) = Yanade P.I.
Please sea Informalion About Your Account sadic n for the Calanianon of Balanw Sttiem n !ntereet %W, Annual Renewal Notice
How 10 Avoid Yneresl on Purdl?_ and drier imporlanl mlormation, es appl ceas
8467943
This Statement Is a Facsimile - Not an original
X. rcoomr wsauaeors mo w z f2 1d 2 PW2a2 oseae --w se+n laznmooramma. lent
4of5
Payment Due Dale New Balance Past Due Amount Minimum Payment
06/09/10 $9.092 70 $2 073.00 52,405.00
Account number: 4185 5060 0210 1215
?? Mewake your N.ack pantie co:
Ch.- Card Se-i-
Plea_.ddadd amount enclosed
Nress v emfl91 Print on Deal
41855060021012150024050000989270000000000000003
Sr3roao z3azoo :,..i(1.l..l..i.l..L.it...ld...J(.l.L.,;LAII.-H"Ij,.I
S ARLEY ARNOLD
1142 PHEASANT DR N BAR DMEM ZER SERVIC:=
t,ARLISLE PA 77013-1251 PO BOX 15753
WILMINGTON DE 19986-5153
t:5000 1,60 2Bt: L99600 2 10 1 2 L 5 11111
CHASE O klanage year aeeou a onllnr Additional wntaa lnton-tion
www chase wrrV-dtcards ccnveni-dylacatad onrevvrse side
ACCOUNT SUMMARY
Account Number 4185 5060 0210 1215
Previous Balance $9.559.29
Fees Charged xS3900
Interest Charged +S19441
New Balanco $9.992 TO
Ope ."g/Closng Date 04!13/10 - 05112/10
Total Credit Line $8.500
Avadahie Credit $0
Cash Access Line $1 700
Availeble for Cash $0
PAYMENT INFORMATION
New Balance $9.892 70
Payment Due Date 06/09110
mnimum Paymenl Due $2,40500
Late Payment Warning ll we do not receive your minimum
payment by the date listed above. you may have to pay up to a
$39.00 late tee and your APRs w If be su bI c_ !o increase to a
maximum Penalty APR of 29 99%
Minimum Payment Warning: If you make only the mnimum
pey-ehl each period, you will pay more in interest and n will lake
you longer to pay oil your balance For example
If you make no You will pay oft the And you will end up
adddionaf charges balance shown on paying an es9maied
ising this card and 1h1s stal.-I n total o1
each month you about.
PaY
Only the minimum 34 yeas $29,506
payment
$391 3 years $14.062
(Sawngs=$15444)
n yocr would like sm, - -,,on about credo counseling services, call
1-1366-797-2885
The oulslandng balance on your aedn card acmunl ',s -hedu3A.11. be wntlw If as a tad debt shortly Asa result. your credi
bureau will be updated win a negative reiing that could less for up to seven years We can sub help, bul you need io qt us now at
1-888-792-7`_47 (colleO 1-33;2-59482x,
Important M- age You Are Ovedim it
Your statemerl? balance exceeds your credit the You sh,t Ad rr,:rlvs a (eyrnen) V-I n dud es the ov.rfmit am, unI;, bring the
balance under your credit line.
ACCOUNT ACTIVITY
Dale of
Trensacbon v-char; Name or p an sactron Desc-otcn $ Amount
KE>=*kRq*0:
05/09 l1.'.=FEE -- 3900
o ;A'. FF'. `OR THIS PERIOD F=900
(?1??Rf3F':GFERtiL.rEF?
05/12 PURCHASE INTER CSI ' `1ARGE 10
0!1/12 PURCHASE INTERFF? HARGE 19431
TOTAL N' -;EST FOR THIS PERIOD $19441
_ FA1A?d/itl7sXeptr7p•()iisTotal I ?s charged 2010 $195.00
T tai e n .1 in 2010 $750.44
r . deli locals reflect all charges minus any refunds
_ .•ri fc roar -ounl on nr atler January 31, 2010
INTEREST CHARGES
Your Annual Percentage Rafe (APR)
arnuel imeresl rate nn your e..wur;
Annual 9a1anoe Accrued
8467943 Percentage'ate(APR) Subject To Interem Interest
30 Day!; ? ,_'ycle Interval R.I. Charges Charges
2424:. $9,75285 $19431 S;'J 00
24 211 $520 solo So 00
This Statement is a Facsimile - Not an original
-1 F3ra33;v. D 13 Q,r` v
R Z 12 1vTV12 Pan..1 y2 05696 M?v... .,
. tylap^ph:1n0e6ar 1f4rY
22 of 25
Statement Dale 04x13/10-05/12/10
Account Ntlnber 4185 5060 0210 1215
Page 2 01 2
INTEREST CHARGES CONTINUED
Your Annual Percenlage Rate (APR) is #* annual imarest rare on your acmunt.
Annual Balance Accued
Balance Percentage Rala(APR) Subject TO trttsroat Interest
Type 30 Days In Cyde Interest Rate :harges Charges
Cash Advances 24 241/. iv) 10 !b SO 00 S31110
Cash Advancas 2424'/-(.) $000 So 00 SO UO
(v) _ Va-tae Rwe
Please see Intormahon About Your ACmunt secaon for the Calculavon of SaImm Sugea 10 I,teresl Rare Annual Hen- Notice
stow to Avoid Inleresl on Pvchsses, and drier irtponam inlo".alion, as a(phcat e
8467943
This Statement Is a Facsimile - Not an original
z woooaf FS 13aD s v M Z 1tMIxt2 PmW2d2 65H8a 1 --- 1-,
. C O ]epOY>> :_
24 of 25
CERTIFICATE OF SERVICE
A true and correct copy of the within Plaintiff's Motion for Summary Judgment and Brief in
Support has been served by U.S. Mail, Postage Pre-Paid, on day of 2011 upon the
following:
Marcus Mcknight, Esquire
60 West Pomfret Street
Carlisle, PA 17013
By:
Matthew D. Urban, Esquire
PA ID# 90963
Weltman,Weinberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
WWR# 8467943
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, NA,
Plaintiff,
vs.
SHIRLEY ARNOLD,
Defendant.
Case No.: 10-6462
ORDER OF COURT
AND NOW, to-wit, this day of , 2011, upon Plaintiff's Motion for
Summary Judgment, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that said Motion is
GRANTED and Judgment is entered in favor of Plaintiff for $9,892.70 with interest at the rate of 6.00%
per annum from September 28, 2010, plus attorneys' fees of $300.00, and costs.
BY THE COURT
J.
W WR# 8467943
OP THE PROTNON?TA"
r1
2011 APR I I PH 12: 22
CU PBEMM'FFRLSAyyND COUNTY
IN THE COURT OF COMMON PLEAS OF CUM$ERLAJNTY, PENNSYLVANIA
CIVIL ACTION
CHASE BANK USA, NA,
Plaintiff,
vs
SHIRLEY ARNOLD,
Defendant.
CIVIL DIVISION
NO. 10-6462
TYPE OF PLEADING:
PRAECIPE TO WITHDRAW
MOTION FOR SUMMARY
JUDGMENT
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD FOR
THIS PARTY:
William T. Molczan, Esquire
PA ID# 47437
Weltman,Weinberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
W WR# 8467943
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
CIVIL DIVISION
CHASE BANK USA, NA,
Plaintiff
VS.
SHIRLEY ARNOLD,
Defendant
NO. 10-6462
PRAECIPE TO WITHDRAW MOTION FOR SUMMARY JUDGMENT
At the request of the undersigned attorneys for the Plaintiff, you are directed to withdraw
the Motion for Summary Judgment on the above referenced case number.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T. Molczan, quire
PA ID # 47437
Weltman, Weinberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
WWR# 8467943
CERTIFICATE OF SERVICE
A true and correct copy of the within Praecipe to Withdraw Motion for Summary Judgment was served by
U. S. Mail, postage prepaid, this %wNday of, 2011 upon the following:
Carole J. Robinson
43 Country View Est.
Newville, PA 17241
By: T
William T. Molczan, uire
PA ID # 47437
Wellman, Weinberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219