HomeMy WebLinkAbout10-66930 P
F'l 3: 29
'F"" CMIJHTY
P 'E!.Y?3 L`*'i"4?iIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
PRO CREDIT SOLUTIONS,
Plaintiff,
Vs.
Ginger R. Riland,
Defendant(s),
CIVIL DIVISION:
No. 10 - WA-3 Cwtl 1er tv
TYPE OF PLEADING:
COMPLAINT
Filed on behalf of
Pro Credit Solutions
Counsel of record for this party:
Thomas L. Maher, Esq.
P.O. Box 582
Greensburg, PA 15601
(888)-793-3238
PA ID # 207970
0
49.1.60 PO PWF
e? ? iso
?? .149987
COUNT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRO CREDIT SOLUTIONS,
Plaintiff No.
vs.
Ginger R. Riland CIVIL ACTION
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and
notice are served, by entering a written appearance personally or by attorney and filing in
writing with the court your defenses or objections to the claims set forth against you. You
are warned that if you fail to do so the case may proceed without you and a judgment
may be entered against you by the court without further notice for any money claimed in
the complaint or for any other claim or relief requested by the plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
Lawyer Referral Service
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
COUNT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PRO CREDIT SOLUTIONS,
Plaintiff No.
vs.
Ginger R. Riland CIVIL ACTION
Defendant
COMPLAINT
1. The Plaintiff is Pro Credit Solutions. ("PCS"), with a place of business at
P.O. Box 582, Greensburg, PA 15601.
2. The Defendant(s) is Ginger R. Riland ,
an individual with an address of 74 Keefer Way Mechanicsburg, PA 17055, PA.
Count I - Breach of Contract
3. Defendant requested a credit card from US BANK.
4. On ,11/1/2007 , US BANK offered Defendant a revolving open-end charge
account and issued a card to the Defendant subject to the terms and conditions set forth in
attached statement and written agreement, marked as exhibit A.
5. Defendant accepted the terms of the written account agreement by using the
US BANK credit card account number 4006138565608282 for purchases, cash
advances, and/or balance transfers.
6. Defendant was mailed account statements relative to Defendant's use of the
credit card', attached.
7. The Defendant has defaulted under the terms of the Agreement by failing to
make monthly payments as they became due and owing.
8. The last payment of the Defendant was received and credited on 8/18/2009.
9. The within account was sold to PCS for valuable consideration and all rights
under said account were assigned to PCS attached as Exhibit "B".
10. Pursuant to the terms of the Agreement, Plaintiff, upon default in payment,
may declare the entire unpaid balance immediately due and payable without notice or
demand.
11. Pursuant to the terms of the Agreement, Defendant, is liable for interest on the
unpaid balance.
12. Pursuant to the terms of the Agreement, Defendant, is liable for Plaintiff's
court costs and reasonable attorneys fees.
13. As of 3/31/2010, the balance due and owing to Plaintiff from Defendant
was $10,034.36.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant,
in the amount $10,034.36 of plus costs and interest at the rate of 6% per annum
from 3/31/2010 as well as reasonable attorneys fees of $500.00 and such other and
further relief as the Court may deem just and appropriate.
Count II - Account Stated
14. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
15. The within account was an account in writing and expressly or impliedly
accepted by both parties.
16.I The amounts due and owing to Plaintiff by Defendant are based on a
subsisting debt and arise from a preexisting account or course of
g dealing between the
parties.
17. This account is an Account Stated, thereby operating to foreclose any dispute
over the amounts due.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant,
in the amount of 10,034.36 plus costs and interest at the rate of 6% per annum
from 3/31/2010 as well as reasonable attorneys fees of $500.00 and such other and
further relief as the Court may deem just and appropriate.
Count III - Quantum Meruit
18. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
19. The services provided by Plaintiff,by and through its predecessor in
interest, and same were received by the Defendant, and the Defendant received and
accepted the benefit of said services provided by Plaintiff.
20. At all times material hereto, Defendant was aware that Plaintiff by and
through its predecessor in interest, was providing the aforesaid services to Defendant and
expected to be paid for such.
21. At all times material hereto, Defendant, with the aforesaid knowledge,
permitted Plaintiff by and through its predecessor in interest, to provide the
aforementioned services and incur damages.
22. At all time material hereto, the Defendant was unjustly enriched by
retaining the benefit of receiving said services without paying Plaintiff or its predecessors
fair and reasonable compensation.
23. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's
expense, a implied contract exists between the Plaintiff and the Defendant, and the
Defendant is obligated to pay Plaintiff the value of the services described above and in
the exhibits attached hereto, in the amount of $10,034.36 plus costs and interest
from 3/31/2010.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant,
in the amount of $10,034.36 plus costs and interest at the rate of 6% per annum
from 3/31/2010 as well as reasonable attorneys fees of $500.00 and such other and
further relief as the Court may deem just and appropriate
By
Thomas Maher, Esquire
Atty. I.D. 207970
Attorney for Plaintiff
P.O. Box 582
Greensburg, PA 15601
(888)-793-3238
4/41(
Statement of Account
Debtor Name: Ginger Riland
Amount Due: $10,034.36
Original Creditor: U.S.Bank/Elan
Account No.:
Open Date:
LP Date:
4006138565608282
l l /l /2007
8/18/2009
Charge Off Date: 3/31/2010
"A"
Page 1 of 4
U.S BanklNational Association ND
P. 0 Box 2066
Milwaukee, III 53201-2066
00002261
19 111218411411114life#04 Sr?r?relrr?r?re?r?r?11111514111101610411
U.S. Bank VISA Credit Cardinamber Agreemew
This is a cardmomber ag and deociasue, staaamerm CAgmemoun between you
and U.S. Bank National A:ssocisoon NO COntair" rho tennrha that WE apply to your U.S.
Bank visa Crom Card' Accou t ('Accounn aftacive February 3, 2004. In Oft
Agreement You' and your' s uach individual aooepWQ a saticmtah or 11PFh hh9
to the Account or otherwise g to be naponsibla for SN Account. 'We'.
cur' and Ike teeter means U. Bank Natbnaf Jtssociation NO. the k. at the Card
and your Account erodilor. P read 01, Agroomekd cw-&* and keep It in a sale
Owe to make the best use of th Car@ IM, we larva with tMS Account (the C0arr1.
The Agreement boconros e0ecfi(re as soar as you or someone authorized by you (an
'authorized signer) uses the Card or Account but ae later than 30 Calender days attar
we issue and you tail to f0l um tht Card
ACCOUNT FEATURES c4NO YOUR USE OF THE ACCOUNT
t. Personal Use - You lmay tut the Account only for PeCSCdA family or household
purposes. Federal or stake consumer prows" laws may not W" It you use eke
Account for other than pom maQ family. or household PM- In addition, we may
suspend or caveat your'abl ity to Lao the Account or and if they are used for other
Purposes.
2 Account Purchases -:.You troy use the Account to buy, Isaac or otherwise obtain
goods or sorvices from pa merchants (Including transactors you inalab by
malt. telephone or over the or take advantage of special promalonal
Co mrenience Chtedc or Transler offars that post as Purchase transactions
('Purchases'). vtfe wi.? in wmh any pranudonal Balance Translor or
Conwnloce Cheek offer we provide you wilt rrnaI, ''s that explain whether
those transactions w8 post and Neatod as a Purchsso. Even It you have not $igned
a sales draft or the morchanthas not supplied you wsh a writen aoelpt or other proof at
sale. you are responsfiile for ant Purchases nude through the Account except as
expressly limited by applicable law (see -four Bring Rights' section below for more
detains).
3-ACeaunf Advances - A'dven are transactions o0w than Purchases that allow you
farad access to funds available rough your Account Advances may include Account
transeedws such as cash you obbin dirom from us. other participating
fhlancal Institutions. o0 th4ter nneihines 'Cash Advar-C). telephone
transfers, sorne Babrocei ram Probetion Advan TCasb . Advance& (-Cash Equivalent Advances"
include transactions to -acquire i or auteb wire transfers. Undo rs checks. money
orders. foreign cash casino gaining and bftV Vansactbns and Mary
tickets. 'Financial insaftoWc.-AT1vr adva ices include horn (automated phone
system). 24 Hsu (GStorer serv, assislad) and Morrell ransfas.) Mouthy Account
statements we Issue Tay to Advances as an 'Cash'. Cash
Advances', or by the prCduel at ice you used to obtain an Advance. Refer to the
Account Foos section file dobk 4n Advance Transaction Fees
4. Advance Limits - No more 211 011 of the Crm* Limit (dolinod below) is available for
Cash Advances. Cash Egdlvafe Advances or Advances requested thro"It telephone
transfers. Unless we halo in this Agroomeet or othawso to finlt the amount
number andlor availability a Advances you may obtain through Overdraft
Proton tion. Convenience C and FaslCosh transactions, you may use the
Account to obtain those n4dvan up to the afflOhlnt evatable undo the Credt Limit
S. Convenience Cheeks- From t ime to time. we may supply CorrvenkdnCS Chocks for
is* by V o person(s) named an ffi - chedm Convenience checks are drafts that lock
Ike other checks. but are drawn Credit ovatabb in the Account We may. based on
the particular tteets we Take time to lima. provide Canwrtkhhce Checks tat will
7051 and be treated as; an A tics or Convenience Checks that will post and be
:mated as o Purchase. We wR con noction with any Convenience Check we Provide.
ndudo materials that explain wh that tho Convaniece Chock WE post and be treated
as an Advance or as a Purchase Convenience Checks mkal be wfdtan in U S. dollars.
twitmay return a Conveeii-I C oak unpaid if:
'a) the credit available under yo ur Credit Limit is loss than the Convenience Check
amount:
:b) the Account is in dotaus: of
:c) the Convenience Check is Im properly signed or otherwise Taal to conform to our
egutarly accepted stanilards Check payment ConvonlenCe Cheeks may not be
ised to pay the Account or any ob ligation you owe us or our affiliates.
6. Paying and Skipping Payment at Convenience Checks - You must use the number
and address provided in the Last or Stolen Card or Convenience Chock' s - in below
to Mq MM that Payment bo stopped an a Convenience Check. You must eeg us
promptly with an oral stop payment Mquost and than provide us with a written
Confirmation of the stop payment request within 14 colander days. Any stop payment
request we revive vrW rerrhsin h enact for 6 months. unless you ronevr the request in
wdtng before the end of that time. late may pay Convenience Cheeks more than 6
months old Tthere may loo drwmstarnoas under whim a Convationee Cheek muse be
paid. oven t we have roeeived s stop payment request from you. We wit not be gable to
you t we do not honor Your stop payrwd re4+aat under those eieumstanexr:< t it is
detarminsd that a Convenience Chock shotrid have boat paid but was not are wkfi not
ce liable for any consoquenfiat. purtmw er inddeabl daa+agos t wo aced sr good falth.
Our ony obb?dtion under thdrae dXrGlirlgahees rri be to pay the destgaalad payee the
amount of the Convenience Chock and cancel any Charges mussed against your
Account as a result of any wrongful failure to honorthe Convenience Check
7. Balance Translate; - We may permit you to Transfer balances and obligations to the
Account that you owe other calnpanlas or ftnancal insaition& subject to Ste tams and
condtio ns dsoosad in offers we may make to you from time to tine. Balance Tmnsfars
will post to the Aeeount and be soperafay reflected on Man" Account statamags as
Balance Trarslar? or. dependitg upon the offer. may post lc the Account andbe hoofed
as a Purchase, Cash Advance or some other kind of Advance bansoction. We wit in
connection will any Balance Ttanstar offer we make. provide you with materials that
explain how the Balance Transfer will post to the Account and be reflected on Monthly
Aoeatm soonwnle. You may act mgLIM Bebnea TnmWom of axtsiing obigolim s you
awe us cr our a IN - . # you vaq ueat a Bahme Transfer that would cause the Account
to ascood ft Credit t N A we any. at our option. (*)_pod the entire Balance Transfer
requested to a your regAsted to your Accouunt ?up the amount d edit
B TTr avaidibla under
Ike Croft Limit or (c) retire to process the entire amount of the Balance Transfer
requested.
9. Overdraft Protection - This soetiak is part of the Agreement only t you have
speeflaify ragresfad and thaw obtained Overdraft Protection linking rho Account wth
a designated checking account at a financial institution wok wit" we are of fated or
with which we have a An Overdraft Proballon Advance atiows us to transtar Account
tends and prevent overdrats on the designated checking account You authorize us to
malty Overdraft Ptobctan Advances from Ire Account as provided In this Agreement
Any Overdraft Prolaeton Advance heir post and be treated as an Advance drawn on the
Account An Ovekdnadt Prolactont Advance will be., only once per day. and will be
11 in multiples of $25 (regardless of tho spvkdlic overdraft amaurM. We may cancel.
Overdraft Protection oriviagosundar Ito Account even t to Account remains open for
other purposes. Nos E Overdraft Ptotactioa Advances on correspondent accounts
may not be in rrogfplos of 575. will pastas a "Financial InsttKien AdvonW. and will be.
Sh>a)act to those tees. Plesso vorty tho amount of the Overckpit Protection Advance
with your tlnancielktaftmon.
FINANCE CHARGES AND ACCOUNT FEES
9. Account FINANCE CHARGES- FINANCE CHARGES teteei the cost atcl Your
total FINANCE CHARGE for any biting eye* Will equal the amount of any (a) periodic
rate FINANCE CHARGES (soreftes rofsrred to as 'nluosr here and on n m&y.
Account ssslomenW: (b) Advance transaction toes: and (c) any other transaction toes
that are considoved FINANCE CNARGES. In some of the following sectlons. we have
abbreviated the tarns -d* pariodc rata' as -DPW'. 'average daily balance' as
ADS": and "annual percentage rate' as "APR".
10. tnbrest Role -
(a) Variable Rate for "Purchases". Variable Rate for "Balance Treenstsrs and
Variable Rate for "Cash Advanaa". The Dally Periodic Rate for transacts ms posting
as Pumbases, Advances and Balance Trarrstas is equal to 1 W tt of its co neepondrig:
ANNUAL PERCENTAGE RATE. The standard Daly Periodic Rate and correspondhng
ANNUAL PERCENTAGE RATE ("APR"} fortrarrsaetons posting to yaurAccomt
as Purohem. Advances and Balance Transtas are varlsbte totes that may change
lion. Coro to tree based on changes to a pubtshod Index.
Your Daily Periodic Rage and conesponding APR may increase or decrease from
tine to time according to me movements up or dawn of the trtdox. which is tho highest
Prime Rare pubnshed in the -Money Rates' sector of the Midwrest Edition of rho 14W.
Street Journal on the last business day in each of the three most rocam catender
months before the date on which the billing cycle Closed (in other words. the'stmlement
date-I. Any variable rate adPsWverI based on an Index change will 150 effeclivs as or,
Page 2 of k
the trot day of rt
bOn
billing ycha,
and will apply to the new and outstanding Account
and bans
ub
to that variable rata. We reserve the right to choose a
now inThe s(ratiownaf dories to publish a Prime Rate.
The I Index to is 4.00%. To determine, the standard rates for
transaction nt as Purchases and Balance Transfers. we will add
Index a M5. (raatteing hn a standard Daly Periodic Rate at
j
.02712=% anti pon ANNUAL PERCENTAGE RA'Z'E 019.90%)
To determine the rate transactions posting as Advances, we wl add tie
Index to a Margi996
dAN
d rosuMfnn a Daily Periodic Rate of .0520273956
H
UAL RCENTAGE RATE
f 18
99%
an
a correspon
transactions poon owever.
o
).
.
are subject to a mintmum Daly Periodic Rate of
05476712% (cm UAL PERCENTAGE RATE Of 19.99%)
Currently.
O as Advances,
7
es
l r
emg APR of oftme
."%-l Any vari
rate
a twM will be
as at the trst day d this biiag ce that begins agar a change in the Index, and we,
to all new and
u Account
r
Any
H
se or dsdawse woo, in So
will result in an increase,
aase
FINANCE CHARGE on the t an Increase or decrease b your Mi?knum
Payment and an ineresse or b your Now eabace.
(b) Fitted Doingdtency Rate. the omew ce d an Adjtstmnl Evenr. each Davy
Periodic Rata and APR In onect for new and oulsanding Ptrehase.
Advance and Balance Traaeter eft will twoese from Ink sondwd rates or any
introduebry or promotional raft b a'Dobgmmq lisle. Trio Dobgwney Rate wit
take erect and apply b new and Purchase. Advance sad Balance Trannsfer
balances as of the Ilrst day at Ina g in which the Ad)isINwt Event occurs. An
Adjualme nt Event occurs. a Payment Is thirty MM colander days
past dim once. or whonewer a , bnumPayment a five (5) calendar days past due
twice during the same rumple (1 monte An 'Adjatmeat Evart' fm promotional
rates roams on the *at date of Year promotional rule we expire upon an
Adjustnent Event and coil De to the DoRmpiency Rate. Each Debquoncy
Rate is a fixed rate that dnvs no vary besatl an dthangoa tO a published Index. The
Dobquency Rate rv apples to Purehaaaa and Balance Ttansiw balances will be a
DalyPeriodic Anteof.06 (Corraaprndn9ANNUAL PERCENTAGERATE
of 23.99%). The 0
? that apples to Advmce balances will be a Dady
Periodic Rats of
72t)02% (corrwpondbg ANNUAL PERCENTAGE RATE
of 23.9996). The Dofrgtdney R for all Account balances will rem on in Offset until the
closing data of fins 6th being eyrie that your Account is currwr (that is.
no Mlnimum Payments past due}. Om the rust day of the bY4fg cycle blowing your 6th
consecutive CumenteyOlal the Pertode Role (and cornopatding APR ) tar
Purdnso. Advance and Bala rmfsr balances will decrease to their standard
rates (not any in"aictory. o dlsoowlad reaW. An increase to your Daly
Periodic Rate will to" Imam in b fro FINANCE CHARGE on you Accatrht.
an increase to your Minimum P and en lacrosse to your New Balance.
11. interest FINANCE CHARGES . Method of Computing Amount interest -
b
We calculate the Periodic rate HARM by
interesr portion of the FINANCE
rho appldabli daily rab -DPR" by ace Average Daly Balance
now tratsecdo+s) o the Purchase. Advance and eafaanea Transfer
detegertea subject to interest (' St?kd b intermit. and than adding together
taw rodtuOng interest icrfh each We determine the Ave" Daly Balance ly-
("ADS") soparat* for rho P Advances and Balance Transfer categories.
TO each coapory, we add the do* balances to twos cemagories for the Ming
cycle and divide rho result by ins of days in rho bisrtg cyde. We delormine rte
dally balances each day by Wdn me bag' Ing !> of those Account categor(as
(including any billed but unpold intonst foss. awll beuraace charges and **or
charges). adding any new loos. and charges. sod sd>Dtacag any payments Of
weft applied against your balames that day. We add a Purchase. Advance
or Balance Transfer to the balances for those eesegerlas on the later of the
transaction date or the first day Ire saraaeat period. Seed but sahpaid interest on
Purchases. Advances and Transfers is added to time al; F; -min balance$ fa
those, categories secs month the sbbw*M date. Bled but unpaid Advance
transaction loos are added b 1i Cash balance of the Account on the date they are
charged to the AccmmL Any but unpaid tees on Purehaes. erodn insurance
charges, and olhar charges ere
b the Purchase balance of to Account an the
dab tbsy are charged lo,te nt. Billed but unpaid tees on Balance Transfers are
added In No Balance Transfer of to Account on 00 dale they are charged to
the Account In other wards, and unpaid interest teas, and charges we, be
included in the Average Daily of to Adxcuat that accretes interest (Lille
'Amount Subject to lyd*nw) an will raduca to amount of I 1 0 avaieble to you
Exceplen: Credit insurance are not included In the ADS calculation to
Purchases until Ile lust day Of bferg CYCID plowing rte Alb this pads Inattance
pron*" is charged to the Aacu There is a misirmum FINANCE CHARGE of 52.00
in any billing eyrie in which a FIN CHARGE Is due.
I?- Grace Period - You have a 20 b 25 day grace period for Purchases. (including any
promolorhal Balance Translas or CaawNence Chocks that will post as Purdtaes).
provided you have pad your P - 8alanoe'at $A by the Paynml Due Dab shown
on your monthly Account In Order to avoid addli nail FINANCE CHARGES
on Purchases, you mist pay your
on the front of
o
nh ew BaWm in ful by the Payment Due Oab sham
d
T
y
ur mor
y r
4snm mt
here s no grace period for
transactions that post d0 the M as Advances or Balance Trarasters. Tine
tranlaethares are subjectb interest, hom do daft they post to Be Aexamt unt the dab
they are paid in *A
I& InrOducbry and Promotional - We may. at our option. offer you to a muted
time inteducbry or promotional in rain for all or part of to Purdhase. Advance.
or Balance Transfer balances In the Account We will tell you this introductory or
prormotiwhat rate and tie period of Atfblg which t is la emaet inthis otar. Unless an
offer antes otherwise. an In ar promotional rob wo geetaly remain in ester
una to last day of the biling eydq which rho introductory opraeoltnd tale expires.
me dsM the Account Isidosed kuuro traaaaetinaa or Me dote your Account that
becomes Past due btceuse a m Payment is rot recoh in en on or before its
Payment Due Oats. tvb @vat occurs soother (the *Termination Dab'). Any
introductory at prrunotbaal ram a lit applas to now or ouWandfng Account balances
wig Increase to me atth A rd role that would otherwise apply. or. when apprep me
under the teens of this Agest ent a Detbtqu"ey Rats. two do not receive tt last the
i lnitnmh Payment die-by the aynhent Due Date shown an a monthly Account
statormnt in any month.
14. Account Fees - You agree to Pay the following Account toes and FINANCE
CHARGES:
(a) We will add a FINANCE CHARGE to the Advance balance of the Account in the
form of the Advance Transaction Fees disebsed below flu each Advance you obtain
dung a biing cycle. The toes imposed ws equal the greater of tin tee based on a
disclosed Percentage Of each Advance or the minimum dollar amount with the
maximum Advance Transaction Fee, shown below. All Advance Transaction
FINANCE CHARGE fees fisted below are in addition to the Interest that accrues on
ACCatfnt Advancos,
CASH R60M FROM CASH FEE % MINIMUM MA)OAIUM
CASH EAUrVALENT 4.000% $10.00 NO maxkmnn
ATM 4.000% $5.00 No Maximum
CONVENUP" CHECK 3.000% $5.00 NO MaaMum
OVHDRAFT PROTECTION 3.000% S&M No MaXimmn
We will add a Balance Treralar Fee FINANCE CHARGE to the Purchase balance of
the Account equal to 100096 of Ire balance transfer amount subject b a minimum of
35.00 and a mindris m of (No Maxi ium).
(b) in adidlon b ehtarea yeurAceourm may be subject to a FINANCE CHARGE in the
tome of a Promotional Discount Transaction Fee for each Promotional Obownt you
receive tiring the bttrdg cydt, as cussed in any Promotional Discount oftr we extend.
(c) Ann" Membership Fee.
There is no Annual Membership Fee an your account
(d) We will add a late Payment Foe to We Purchase bad at tho Account I your
Mil kwin Paymmt is not rocobted by the Payment Duo Dots shown an the monthly
Account stalort+ent
During any period of twelve consecutive months. the W 2 tires yam payment is Iota. a
529.00 Late Payment Fee will be assessed. Submquent tines Yom Payer is late, the
tall Payment Foe will be $35-00. The Late Payment Fee will be rodmod to $29-00
whon you have had two or fewer fate payments in the prior period of twelve consecutive
-
months.
to) We will add an Overlm6 Fee of 535-00 to the Purchase belance of the Account if
you exceed your Credit Limit at any lima during the billing cycle. even I this occurs
became FINANCE CHARGES or other fees are messed on the Axbount on any day
on or betae your statenentcycle data The Ovorbdt Fee disclosure w5 be determined
by your state of rot'' ce. For KY. Mt. OH. and TN. the fee will be disclosed as
Ovedmit Fee FINANCE CHARGE $3S.00. For residents of any other stele the We will
'
be disclosed as Ovw*M Fee 535.00.
M We will add a Rearmed Payment Fee of 535A0 to rho Purchase balance of the '.
Account I any payment an the Account is not honored or if we must return I to you
because I cannot be processed. A check that is returned unpaid will be sent to
colrelbn.
(g) We willadd a Rewmod Cmwenionce Check Feed $35.00 to the Purchase balance
of the Account I you wd* a CorveniaeO Chock tat we do net honor under the toms
of this Agreement. (So*'Co venioneo Checks' and'Paybng and Stopping Payment on
Convenience Chocks' sections above for more dMaNs.)
(h) We will add a Dupiiab Daamantatiom Fee of $5.00 to the Purchase balance of the
Acownt for each copy of a monthly statement sates slip. rotund elp. or Advance W
tut you regva There will be no charge for documentation requests made in
connection with a blGmg error notes. V our invesigatrn Indicates a bitsng error
occurred.
(l into will add a Phone Pay Fee FINANCE CHARGE of $15.00 to the Purchase
basxrce or the Accwnt N you call us to make a payment on your Account and are
assisbd by s axslomrr sevko repressetamMa lib nelw tho psyyrrrreont
({7 ift will add an Acemm AfedmgeateM Fee FINANCE CHARGE of $250 par month If
you voluntarily close your Account wile a balance. (Secured accounts are not subject
t0 this tea).
IMPORTANT INFORMATM ABOUT US64G YOUR ACCOUNT
15. Insurance Charges - Credit 6le insurance and d bMwence are not rGgLdmd
to obw n CradiL If you are eKS', W. you may I araeipal, In a graq Credit Card instance
program which we have arranged. t you elect Insurance coverage. an bmwence
Premium charge tat Ire rob dsd=W b you) ws bo added to the Purchaso balance as
of the closing data of each billing cycle based upon the Account balance (Including
armed FINANCE CHARGES ). The tarts of your insuuance coverage will be
Slrmmadied in the Cer66rau of insurance. which wig be provided to you.
IS. Crodt Lin(! -The Account Credit Lkrit is the maximum amount W crtdl avabbte
and that you may owe under to Account at any tyre. You may not reghwst or obatih
edddi0rtal Purchases. Advances or Balance Tracks once you have reached your
Credit tams The inlW Cede Limit is shown on the Card carrier and will also appear on
your monthly Account statements. coo reserve the right to review your Account at any
time and increase or decrease your credit Lint! You may ibt increase yaw credit Limit
by carrying crash balances over t1e Credit LAM we make avalble to you. (Also an
to *Advance Lr section above for more bfdrtal0n about Wit on Cash Advance
,
Cash Eqjwa*mAdvam*andt*ohomtmswftraactom).
17 Payment - You mat pay us in U.S. dollars with checks or sinlar paymentwsinments rrawn an a Tinmcial imltruton bested In the UMlad States. We may. at our
option, choose to make an exceplion and accept a payment ttavnh an a foreign bank. .
Howwor. you will be charged and agree to pay any CnteCtrrh foss rocoimd in
connectors wick such a transaction. The date you and a payment is dlllarerd than time ,
date we reeain that payment For purposes of this Agreement the payment date Is 1ho
day we receive your check or money order al the address specified on your mombly
Accwnt statement m you mail your payment without a payment coupon or to an
incoaect address. I may react In a delayed tradt to yaw Account This may result in
addlionat FRANCE CHARGES. foes, and possible suspension of your A=unt
IS. wr emon Manny Payment - Each month. You must Pay at beat the Minimum
Payment and aRy past due Ntntmum PaYrnnht(s) by the Payment Die Date shown on .
yow mouthy Account sta2madt. Yon m W. at your cP*M. Pay more than the Miniumrm
Paytrhsnt or pay the Now Balance in rum to reduce or avoid the interest FINANCE
CHARGE Mr the Accotia TIN LoWnum Payment is squat to any Annual Mianbership
Fee due. pits Ire gMOW at S1Q00 Or P OD76 of your regular Now Balance rounded to
to nod Ihi9hhae daft at the tul amwat of any regut Now Balance loss than $10.00.
Any M6Wrum Payxwd or additional amount Ycu Pay each month will not prepay any
fttNMV LAihiwrm PaYawns M41
IWnlmum Paymeatby tow Payme 6d a change Yoe obligation to mace at least a
*t Due Date.
19. Payment APptieato u - WO of" payments, to prOM611 net or discounted interest
rats Purchase. Advance and Bs Tronsterbefantas before we apply payments to
highs rata bsler+us. If we can cdsct your toad[ or other payment hem withn a
roaaonabie Period of time. we
any aaddit previouW gtyen and post as Advance transaction the turf amount of
rge Interest on the ameunt from the posting dale of
the transaction. After a ps
wilkhold available credit in the t has been mate. the Issuer reserves the right to
at the psynant la 7 business days. Any craft
avalla * before the payment is wig continue to be available for use during Iris
tarty.
20. Skip Payment Option - Yye
t
to
bi
'
' at our option. ocraa+awh elect you an
oPPaaY
You may not Skip
rrueat due
the Minimum Pa
on
year a
pa
[skip
to
payments unless we rowu tins y
.
to you. You may At up to two (2) tsaYmnds in
od
twelve (12) months w6dut in y
a Late Payment oo but those two mon
paymets meY not be pahyaans that are requied in canseawhra orhonths You danthot
use a *0 payment Wow 9 Account s stlb(ect to a Dointlueney Rase. is
otherwise delinquent of is in IL VAM You taste advantage of a Skip Paynant
option we offer. the interest wilt to accrue on the entire unpaid batdtce of you
Account
21. Change of Address - Your tiny Account staimmons and notxss about your
oe
Account wa be sentte tlw add
our Account soidtaton. To cha provided in yaw application or your response to
" you
yeas address you moat tai us at 1-800.285-8585.
(FAX 1-701-461-4022. TOD 1
P
B
O 2 B?SSi or wtte to us it me follow g address.
NO 581256352 We must receive this
o
6352 F
ox
.
Cadmember service.
.
information 15 days boftxe the
Account statement at your new ,
.
arg
bOW geft doses to provide Your Monthly
m a
cra
Nolte: 9 you have an address change wain
ass
4S MYS of the expiratipn date your Card(s). pteae contact Cusionar Service at
1.80D-2855585. (FAX 1-IM-446 -4(22 TOD l4MS-352.6455) with that tnormation so
your new Card(s) can bb nailed to your new address
22. Autho ized Signors 1 You or any other Account obligor miW ask us to issuo a Card
and otherwise give Account to a person authorized to use the Account Thos
person is called an Xt(Otaized signet'. You ogres to be responsible for an Account
transactions made t any a ch ortzed signor. You agree not m give Your Card to
anywo else a allow anyone
give your Card or Account than an sulhor¢od signer to tae the Account If you
to someone other Man an ouharized signer. you sea
be fable to any charges nude that persm unless and except as sxPt eaW requied
by applicable taw. Ydhur.; ss a P ry or pat Cadres ba and Account obligor. must
tall us at 1.800.2658585. (F 1-707-461-4022. TUC 1-888-352-6455) or write us at
Cardnernber Service. P.O. Ba 6352. Fargo. ND 581254= with any request W
tenet and remove tow Aaou authority of an susiorized signer or any tuna person
groan access to the Account
23_ Lost or Stolen Card or Checks - You must no* us anaadramy A
your Card or Convenience C are test or stolen or this is Possible unslborized
use of your Cad. You lira not NOW for unauthorized use of the Account You must
notify U_S. Bank Na Wad ND by tateP cone at i4W-2554M. (FAX
1-7ot-461.4022.TDD 1 5). or in wrung at P.O. Sox GSM. Fargo NO
58125 352. It this happane
a will ask you and all attar persons given Recount
enience C *sttet o our
, Con
i
rds
atolls to rearm a0 C
ktvestip Dopammerii in v
esce
unused Conves
we thaw the r(gMto close your Ac oust and open
a new Account It we do so. cards and Ctmvenieesee Chocks will be issued for
your new Account
24 Using Your Card Ina F ' Country.
-
For VISA Accounts - You stay es at foreign
s
use Your Crad3 Card IW retaa Purcha
Outside Me UnIled 6) a bow ar $0 PLUStoSyste Mn or ei
y
VISA togrhi. If you me Your cardan ATM that tsars
only the PLUS System ego ( no VISA ego), the charge will be processed through
the PLUS System sad WE coaveried into U.S. dollars at the exchange Mete
established. tMm tine m time. We operator of goat ATM. ORS one percent of the
I"& it you use Your laud at a or an ATM Out boas me VISA boo (and no
PLUS System to"). The chage be processed anugb the VISA system and wa be
convoried into U.S. dollars tc On applicable bylines and ales established by
VISA from time to tine.i9 you ydAr cold at an ATM that beats both the VISA and
PLUS System logos. tM ATM will dolemnite whether to seed your UWM*cfoch
over the VISA or PLUS S netwo t using, such eeteaks MWoctlvo Cunancy
conversion tutus then in Mass ou understand out the exchange rate in dtteU when
ate dome is processed may from Vwe not in clot( on the dab o)1he transaction
or posting to Your account amount at Your aaafa:fort in dotes n processed
through VISA (under Its casrrent saddttW vibe:
(a) The amount of the tdieign ncy tknes sit anchango ram in elect ono nay prior to
the processing data that s:
i) the government
rata if tteere s ode. or
if) if owe is no mantlefad teat tw wttoiesale market rasa, pos
(b) One PWC-t (l%) Onus the data anouuk pies
(c) Our fee of 2% tarries the sum s ubpawgAphs (a) and (b).
YOUR LEGAL RESPONSIBILITY IN THIS AGREEMENT
25. ReapdnssMryto Pay - You *
AAl1 OM to pay us ter s0 Purchases. Advances. Balance
new "as=UM
hot
es
an
d
F
Travelers PNANCE C I
F
charges, as poovidod fa{thk g
.
y
c
Account
ees an
and. 10 the erttertt pe nNod tinder applicable
law. attorneys toes and. casts we incur enmrcig this Agreement against you
This 15 the case even d the at is only used by one of you. or le used by an
outkorized signer 005" by an one td you. O there is mac that one Account Holder.
each of you It roepensibw. and sepershey. for the hue amount &Aod an *0
Account
26. Intent W Repay - Every you use tine Account you represent to to that you
intend and have the -bay to r*M your Account obeee ions. We rely on
tits ntpwsentatton wary We yo ke use the Acm at
27. Setting a Deputed Balance. Payment in Fun - it you want ro satddr a disagreement
Page 3 of 4
wih us about any amount you owe by sending a check on whidn You have wrleen
'Psymant in Full" or almost language. You must trend us a written explanation of the
dnsagroemeM or dispute and any such check to Carertwmbar SofvkO. P.O. Box 6335.
Fargo. NO 58125.6335. (See'Your BltWng Plights' section below for ootnplsla dttftt?al
This address is dftereet than the addross you use to make Account payments. Wtitg
payment in fur' or similar language on thecheck wilt of beQ enough a l Y resolve Mo
dispute. ltwe cotiect a check or any payment In
sent to art address other than the one provided in this section (such as the address at
which you normally make Payments). we will not have waked our right to do9act any
remaining amount you owe us under the tams of the Account
28. Default - You and the Account will be in defaul Payment Due Dam tfscinsed on the
a) you do oat make the Ln almian Payment by the momhy Account statement
b) You vk" any dither provision of this Agreement:
c) you dote wilhou a aavlvitg.toint Account Holder.
d) You Insolvent assign any property to your dredeors. or go into bankruptcy or
e) you have made false stamnuns eggs c5hg the application or maittenanoe uhf Account:
9you go eve feet
g3 we have e my any meson to believe that tiw AoxcuM is in danger of. OF is being used for
usuct
h) you are a married domm unit' PmPwW stale fasidsnt and you or we receive a written
torminstion aofcs of this Agreementtiem your spouse. or
h) anything happens tiro!: we believe in good falth materially Increases tho risk that you
wa notive up to psymom acrd oewr obayalions under this Agreement
29. Illegal Purchases - The Card not not be used for any unlowful purpose. such as
funding anyy account tiers sot Lip to taeamm onloe genOing. You agree that you WE
not use or iahdhwingy permit another to use use Card or Account for any transaction teat
is itegaf under appiabls law.
THE ISSUERS LEGAL RIGHTTO CHANGE OR CANCEL TWS AGREEMENT
30. Ownership of this Account Governing Law - Your Card and any other Account
access devices that we supply to you ae our property and must be immadaWy
returned to us or our QWVWakd agent or othowso MSMWod or tearendered as we
ianhucL We attend ail Account CrOl to You In and from the Stain of ROM Dakota:
regardless at where you reside or use the Account. This agreement is governed by
North Dakota taw. and to the exww necessary ft f itlBreSt exportation or consumer
prolection purposes. by tederdlew. regardless a the rtematountict of law princpl s oR
Me state where you reside or use Me Account if a dispute arises and you life a lawsuit law
the Ua S Bank National Asso ?S?Avenue SSW. Far". NO follm 0g address:
31. Changes la the Aacunt - We may range of or any Pat of the Agreement at any
tlnwwhen we notify you in wrong Wswill"you the arise olasy much change nn rite
marina required by Mat Dahad and %deral law. The fanged to.. will appy to an
raw and outstanding Account babocas and everylift you awe under e Account as
of tw offocl a dots ndicmd b fo acks m law
you do not want to aowept the changes. You must provide us wile wrMtaru PCOM: at the
address ecntairn- it Ow Change in Terns tt, If a no tefer than 25 days attar the
ellseaive dote at the change. in tins cad. we will does your Account and permit you to
pay off the cumooding Account halo neos in kuf at 20 tlfrw or under the /errs of yam
exleeng Agresmesl You will haw accopled any proposed Change I the Account is
used after the orbclwe dale of the changed terns. even it 25 days has not elapsed after
any such anedke date.
32. Co ncseafon of your Account - We may cancel your Account or suspend your abiRy
to obtain Account craft I mod k". w*MX notes. 9 the Account Is In defout Even it
you are act in default. we may cancel to Account by providing active to you. You may
cancel your Account by notifying us by WIPhome at 1-800-2554MS. (FAX
1-701461-4022 TOD 1.809,152-64S5) or in wr" at Cardmernba Service. P.O. Box
6352 Fargo ND 5812544 "you have a Secoved account you r lormieatiah request
must be suds in wri0ng and maiedto PO Box SM Fargo NO 981256363, or faxed to
7014613410. If this is a .tail Avant we will honor a request by either of you to
coined the AccWftL After the Account s tsnd_I you will not be able to dlbfalR
additional Account uodflt After the Account is emncellad. the Account may continue to
mosive manning charges for Moms such as buushhoss subspipiore until you c onila t
and cancel detkery wfh the company preovilno rte flem. After the Account is cancefed.
all smornts MAdan6ng on tow Account will be i i r lia" due and payable w*xM
nofte a dleSha110 team us. You roust cut me Cards and Convenience Checks in hair and
wean Oar tous. t you do not pay tow ammunt you am under this Agreement you wa
be liable for our CoMaetion case nclufng out reasonable 115"Sy tees and expenses of
legal actions. 10 the extent pernnrkisd by appseable law.
33. Assignment of Your Account to Anaaer Creditor - We may assign. sell or haaster
your Acatrat and amens awed by You to WOW GrOMW at asy done. N to do. WAS
Agreement will still be In atledx unless and urn anonle4 and all re'tereecaz neds in
We Agreement to NW. W. 'osd or' am issuar' will rota to the cnxaw to which we
assigned. said or transiarred Me Account may not daagele your obligations and responsibilities anwounts to ads toady ththe ird party without
our express wtMten consent
THE ISSUERS LEGAL RIGHTS AND OBLIGATIONS
34. CoMacting Credit m nialion About You - You ail WiW us to make any credL
4 apbymat and moslp&o inquiries we teal are I lieoprhale fabled to ghvig you
crew or eoMudktg amours owed an your Account. Your agree that a dertikmrler CtedM
[sport away be tegrested periodically from one or more consunar reporting agendas
(trees Ahrgahhy aid need lA oeraeseea rtes Your MPFNCStiern and anY update. renewal
a aatmnslen a 1. 1 Wv we Provide tntxmadonabout you. viopereAccount ore
txedt sistssy to consumr[ doporeng agencies d 0006 Mat
information.
35. Credit Bureau Dsptxes - tt you believe we ahaccuestely reported Credit history
infbra>a4thn aboa yes or the Aocoutnt to a c l*dka t D a 4881 106. St
wrke to us at Cons u w Recovery Department
Page 4 of 4
Louis. MO63tN-sect.
36. Privacy Pledge and'D' of Account Infomatlon - You will receive a copy of
our Privacy Pledge wbet you you Account and at least once annually while you
remain our wslotner. We also ke" copies of our Privacy Pledge in bW* Wft@s and
post It on our web sae. Our P Pledge describes how we c odoct Protect and use
your contdenrifi bonito and Goter Information about you and the circumstances in
which we aright stare into atiou wdf? ,members of our corporate family and
with unaWwad third Parties. The'. qrOlvacyPledge also tells you how you can (a) limit the
ways we share certain kinds of lit about yet and (b) request corrections to the
int wmatim we mainfak abedyou
37. Refusal to Monor TIPtrsactiwt - The issuer and ft agents are not resporaala it
anyone reuses a horror your C a a Convenience Chock. or If authorimtlon tot a
Particular t wumefte is'no1 given. Although you may have c?eest avaisDb under the
Account we may be usable to ride exedifora parkuder' avaaetlon. The nuft r
of transactions you malt" w alereasY may be smiled and gee M* Per day they vary
These restrictions are fa soar ons. And as a me* we cannot explain the
deeds of how this system if your ACCOUM is over omit or dNnQuent
authorizatiae Of credit for
s may be tleesnued We are not reapatsible for
nnsa*n
anyMk* purchased wit your Card of a Comwnience Chock. exespe as aquouy
ired applicable few (M YYot m sttrretum goods you Iva oo wBidin ith the Card Accamtt to Me Merchant and
not to cis.
38. Third Party Offers - Fioi$. ins, third parties may provide you with be+naft rret
related a Ste extorsioa of a odic yYe are net Bob for goose faAtures, services
and enhoncomenis. as Ch, asole responsibility at the third patty Provider. The
Issuer w4br a third party change or delete andreyr those benelis without
notice or kbithy to you. to pendged by appiheble law. You ?roa ro hold us
works
ham ms tram stny cbins r damages res oo from your toe 0 any of these
featnnes services o onh5rroertgntS. whon permilled by applicable law.
39. Telephone Mo» truing - From un , to time. we may mwhor tslephone calls you
make tout or our agents:
suDSitentive law consistent With ire FAA and OVACable stsLtes of struilations. and shas
horror claims of privftepo rec o(pated at law. Judgment upon the award rendered by the
arbitrator may be entered in any court having jurisdiction. This Arbitration Provision,
shad survive repayment of your extension of credit and tonntratton of your Account
This arbitration provision shall be governed by the Federal Arbitration Act, 9 U.S.C.
Sections t through 16.
44. If you are an Executive Officer at U.S. Bancorp or any of its bank affiliates. the Bank
reserves the right to demand payment at any time.
YOUR BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE USE
This is imporlant inbrmabot about your rights and our responsibilities under Ore Farr
Credit Bllifg Act
Nally Us in Case of Eam or Questions Abaft Your Bid
If you tank your bill is wrong ore you noed morn intonation about an item or
transaction on your own" bang statement YOU MUST WRITE TO US ON A'
SEPARATE SHEETOF PAPER AND SEND IT TO:
CaMinsmber Service
P.O. Box 6835, Fargo. NO 58t254M
Wrba a us as soon as possible. We worst hoar from you no later than lip days alter we
sent you the fiat bill where the error or problem appeared. You can telephone us. cur
doing so will notpreservo your legal rights under the Fair Credit Baling Act
In your letter. include the fallowing incarnation:
t) Yon rams and Account number.
2) the dr"I amount of the suspected error:
3) me date me transaction occurred (i Possible); and
4) describe ale orror. and explain. it you can. why you believe there is an error. It you
need more otrmefion, describe Me item you are not sure about
h you have authorized us to pay your credit card bit aulor alically from Your savings or
checking account you an stop are payment on any amount you bsiwe is wrong. To
stop the psyrmA jr boor must react us tt roe business days before the automate
payment is to occur.
40. SovorabiNly - It a Court of competent junadietim finds any part d this AgreenreM
i agal or unonlorcombis. the portions 0 tie Agroefnent wit vervain io efteet as
wti nn aller any such liege or Porwn is amended it coniornmce wish
apphabla law or d necessan+.
41. Entire Agreement - This version of the Agreement replaces any previous versions of
the Agreement The Agiieemattt mdtsead by any don" it teems we may driver
from time to time in accordance vft applicable law. COMMItule3 the entire sgraettwtti
bslwMa you and us. and supersedes any prior negotiation or understanding between
you and us concerning the subject Moorm d 2w Agrown-t.
42. Waiver - We d0 not g)va tip artj rights under the Agreement or applicable law when
we tai to exereise or delay axorcoft those rights Our faiure Or delay a exercise any
right or fsmedy we have !against you does not mean that we waive that right
43. Arbitration - By requesting an Account from his and accept" this Agreement you
agree that i a dwtspufs of any kind arises out d Otis Ageen ont either you or we ran
choose to have that depute by Und" arbiayo+. It arbitatfott is ckosen by
any pariY. neither you no we WE o the right to Vdgate gnat dash in court or to have a
jury trio Cn that cisim, or tom in pre4dWalot dscomy etroepe ns provided for
in the atbntratkm rules.min You WE not have the right to panle4sl- as a
ropreietr!atNe or rttaneber of any of claimants pares lit any clam subject io
arbitrstlen. TAO Atbhttatot's ' will generally be tinai and binding OVrerrigMa that
you world have If you ,wont to it may also not be available in arbt'aa9omm. It is
impotbnt that you read6Uee entire rbitra" ProvtSbn earehdy before accepting the
terms of this Agraermt
Any ebir, dispute or eottlrarersy,(whethar In Contract regulatory. art or Otherwise.
whether Pre-existing. Present or to and iroluang wnstikutiotat if?ubry. common
law. Ntentbna art and ) arising from or Mix" to (a) the credit offered
or provided to You. (b) the ahdions of you. is or third panties at (c) the, vanity of this
arbitretian provision ((ntiFrirkaiy d eoioeVwfj! 8'CbinO crest attar an election by
you or us, bO rehnoked by ban in aooarteruoa with this arbitration provision
and the Cemenertaa Arbitraion 0"Anrriotm At?aliam Association ('AAA i
a alteetwhon ttre Ctain?is fled (or in the event gas arbitrator or ttleso arbitration hulas
are no lormger available. than a substitute arbilrallon procedure andbr
arbitration organizatlort fhst does tru a nationwide book). There shod be no
authority for any Claims is be red an s days action basis. An atbitrstron can only
decide our or your Claim end may not consoadara or jeih the chins of oche persons
who may have sit r claims. You may obtain rules and terms by coding the AAA at
000.778-7679. Any arbitration gat You attend wit take place in The tedeat
pdcW district whore you reside. your request. we wit advance gee fist 5250 of the
any and hoanng loss any C. -
for
h
fat, ym troy file against : the asbibalm WE docidEL
M
itimateIr
w
etter we or you will y them Leos The
tor shad apply applicable
Your Rights and Our ReSponstoWas Ater We Reesive Written Notice
We must acknowledge your Naar within 90 days. MM" we have corrected the error by
then. Within 90 days we must ehl6er corned the error - explam why we' am , - the
staff etnerd was correct Alter we meakre your letter. we eafenot try a COdect any amount
you questioned Of report yon Account as tleiMAJIML We COM continua to big YOU tot ire
amount you quossaad Nctlhlthg Finance Charges, and we Can apply any Unpaid
amount against your Credit limit ou do not have in, pay any questioned amount whip
we are in Melgod". but you are SO obigatod b Pay the part of yew Account that are
not in question.
It we find that ws made a mistake eon your bilL you will not have b pay any Finance
Charges rohtad to the quagoto d amount If we lid not mate a melalte. you may have
to pay Finance Charges and you will have to make up any missed PBYm MIS On the
questioned amount M elswr case. we wit send you a sMNWM of Me amfourtt you owe
and the date *0 it is due. If You 1111 110 PRY Vie amount that we think YOU owe, we may
as delinquent
report you w
write
anyonend e th YOU re repot
to us ithin n ton ysda Is" 90 YOU 03 rodeo to Pay. w sus
you to that you have a question abort your bit. And. we must tai you the tams of
anyone we reported you V. We must toil anyone we report you to trot the trailer has
bow soloed DOhveen US, when at * is.
it we don't fellow thasO rubes. we cannot collect the fist 550.00 of the questioned
amount even It your ail was cares
Rules for Credit Card Purchases
n you have a problem wish the quality d property or services met you purchased with
your , , M card, and you have hied in good tail to correct the problem win fire
Mwc hattt you may have the right not to pay the remsiring amount due on the property
or services. Them aretwo Imilelioes on this right and both must apply:
t) You must have made the purchase in )rot, home stars or. I not whit your home
state whAin too miss of your current nailing address. and
2) Th o purchase price test he" bean 010011118111150
.
The Conditions etc not apply d we own or operate the merchant or it we mailed you the
ant for the property or services.
SPECIAL. RULES FOR CREDri CARD PURCHASES DO NOT APPLY TO
PURCHASES MADE WITH CONVENIENCE CHECKS OR BALANCE TRANSFER
CHECKS.
24-2114 4719230653278108
a
Bi xmrr B
BILL OF SALE AND ASSIGNNI OF ASSETS
fers, assigns, sets-over,
") hereby absolutely sells, trans
ed Assignor r
The uPdersign ited liabdrty company organized under the laws of
quitclaims and conveys to NLEX, LLC., a limited ALL FAULTS" basis, without recourse and
Illinois CA'I on. an "AS IS" and "WIC nature, express or implied, all of
or wananties of any type, Idnd, car
in and to each of the assets identified in the Asset Schedule
without Assignor's right, title representations
and interest together with the right to collect all
A, (the "Assets"},
("Asset Schedule")attached hereto as to the Assets remaining due and owing
or other of an ? ?Pect
principal, interest pis derived from the ccsnversion, voluntary or
as of the date hereof Cuicluding but not limited to Proceeds including, without limitation,
involuntary, of any of the Assets into cash or other liquidated pre dabs of this Bill of Sale and
the
insurance proceeds and condemnation awards), from and after
Assignment of Assets.
DATED: Auger 31, 2010.
ASSIGNOR: U.S. Bank National Association ND
By:
Name (print):
Title: Vice President of Retail Loss Prevention
IM.rNL?µ
08/25/2010
e
EXHIBIT B
BILL OF SALE AND ASSIGNMENT OF ASSETS
Lot No.: 81612
. The undersigned Assignor ("Assignor") hereby absolutely sells, transfers, assigns,
sets-over, quitclaims and conveys to ProCredit Solutions ("Assign '), all of Assignor's
right, title and interest in and to each of the assets identified in the Asset Schedule attached
hereto as Exhibit A (the "Assets"), together with the right to collect all principal, interest or
other proceeds of any kind with respect to the Assets remaining due and owing as of the date
hereof (including but not limited to proceeds derived from the conversion, voluntary or
involuntary, of any of the Assets into cash or other liquidated property, including, without
limitation, insurance proceeds and condemnation awards), from and after the date of this
Bill of Sale and Assignment of Assets. Except as otherwise provided in the Purchase and
Sale Agreement executed between the Assignor and Assignee and dated August 25, 2010
which is incorporated herein and made a part hereof as if fully set forth, this Assignment is
on an ' * is" and "with all faults" basis, without recourse and without representations or
warranties of any type, kind, character or nature, express or implied.
DATED: August 31, 2010
ASSIGNOR: NLEX, L C
r
By: -------
Name (pri o as Ludwig
Title: Manager
NLEX
SBE 052010
VERIFICATION
Ia Jason DiNardo, am fully familiar with the facts set forth in this complaint.
I verify the facts set forth in the within allegations are true and correct to the best of my
knowledge, knowing that any false statements are punishable by law pursuant to 18
C.S.A. 41904.
Jason DiNard
Pro Credit Solutions
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
In the Matter of:
PRO CREDIT SOLUTIONS
v
Ginger R.Riland
NO:
NOTICE OF APPEARANCE
Please enter my appearance in the above-designated matter on behalf of PRO CREDIT
SOLUTIONS
I am authorized to accept service on behalf of said participant in this matter.
On the basis of this notice, I request a copy of each document hereafter issued by the
COUNTY OF CUMBERLAND in this matter.
Thomas L Maher, Esquire
Atty. I.D. 207970
Attorney for Plaintiff
P.O. Box 582
Greensburg, PA 15601
(888)-793-3238
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
?,ta of 4uit?brr?????#
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor Ftc.E-jf '?E S":RIPF
Pro Credit Solutions
vs. Case Number
Ginger R. Riland 2010-6693
SHERIFF'S RETURN OF SERVICE
11/03/2010 09:17 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
November 3, 2010 at 0917 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Ginger R. Riland, by making known unto herself personally, at 74 Keefer
Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.44
November 05, 2010
0e4L-j'-'
GERALD WORTHINGT , DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
-:_
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(Cj COLV IfySURO ShPrlff, TPleipgOft_ IitC.
n
VS.
JASON M. RETTIG, PABN 200948
100 WEST MONUMENT AVE
HATBORO, PA 19040
(267) 879-9054
Attorney for Defendant GINGER RILAND
Plaintiff,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PRO CREDIT SOLUTIONS
GINGER RILAND
Defendant.
O ' THELPROTHONOTAR`'
2010 DEC -2 PM 2: 26
CUMBERLAND COUNTY
PENNSYLVANIA
Case No: 10-6693 Civil Term
CIVIL ACTION - LAW
To the Prothonotary:
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance for GINGER RILAND, defendant, in the above titled case.
DATED: November 19, 2010
-9L
JASON M. RETTIG, PABN 200948
100 WEST MONUMENT AVE
HATBORO, PA 19040
(267) 879-9054
Attorney for Defendant GINGER RILAND
JASON M. RETTIG, PABN 200948
418 WILLARD RD
HATBORO, PA 19040
(267) 879-9054
Attorney for Defendant GINGER RILAND
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PRO CREDIT SOLUTIONS,
Plaintiff,
VS.
GINGER RILAND
Defendant.
Case No.: 10-6693-Civil Term
CIVIL ACTION - LAW
ANSWER
AND NOW, this 19`h day of November, 2010, comes the defendant GINGER RILAND,
by and through her attorney Jason Rettig, who admits, denies, and alleges as follows:
1. Defendant, GINGER RILAND, admits to the facts contained in paragraph one, that the
plaintiff is Pro Credit Solutions, with a principal place of business situated at PO Box
582, Greensburg, PA 15601.
2. Defendant, GINGER RILAND, admits to the facts contained in paragraph two, that she
resides at 74 Keefer Way, Mechanicsburg, Cumberland County, PA.
3. Defendant, GINGER RILAND, admits the facts alleged in paragraph three, that she
requested a credit card from US bank.
4. Defendant, GINGER RILAND, admits the facts alleged in paragraph four, that on
11/1/07, she was offered a charge account and was issued a card subject to the terms and
conditions of a written agreement.
5. Defendant, GINGER RILAND, admits the facts alleged in paragraph five, that she
accepted the terms by using the card.
6. Defendant, GINGER RILAND, admits facts alleged in paragraph six, that the Plaintiff
mailed her monthly statements.
7. Defendant, GINGER RR AND, admits facts alleged in paragraph seven, that she has
defaulted by failing to make payments when due.
8. Defendant, GINGER RILAND, admits the facts alleged in paragraph eight, that her last
payment was received on 8/18/2009.
9. Defendant, GINGER RILAND, does not have sufficient information to admit or deny the
facts alleged in paragraph nine, that the account was sold to PCS for valuable
consideration.
10. Defendant, GINGER RILAND, does not have sufficient information to admit or deny the
facts alleged in paragraph ten.
11. Defendant, GINGER RILAND, admits facts alleged in paragraph eleven, that she is
liable for interest on the account.
12. Defendant, GINGER RILAND, denies facts alleged in paragraph twelve as to court costs
and attorney fees..
13. Defendant, GINGER RILAND, does not have sufficient information to admit or deny the
facts alleged in paragraph thirteen, that there is a balance due of $10034.36.
14. Defendant, GINGER RILAND, admits facts alleged in paragraph fourteen.
15. Defendant, GINGER RILAND, admits facts alleged in paragraph fifteen.
16. Defendant, GINGER RILAND, admits facts alleged in paragraph sixteen.
17. Defendant, GINGER RILAND, denies facts alleged in paragraph seventeen, that the
account is "stated" relieving the Plaintiff of proving the amount due.
18. Defendant, GINGER RILAND, admits facts alleged in paragraph eighteen
19. Defendant, GINGER RILAND, admits facts alleged in paragraph nineteen
20. Defendant, GINGER RILAND, admits facts alleged in paragraph twenty, that the
Plaintiff expected to be paid.
21. Defendant, GINGER RILAND, admits facts alleged in paragraph twenty-one.
22. Defendant, GINGER RILAND, admits facts alleged in paragraph twenty-two, that she
was unjustly enriched at Plaintiffs expense.
23. Defendant, GINGER RILAND, denies facts alleged in paragraph twenty-three, that an
implied contact exists between the parties and that she is obligated to pay Plaintiff the
amount of $10034.36
WHEREFORE, the defendant respectfully requests this honorable court enter judgment
in favor of the defendant and that Complainant take nothing by said Complaint; that
Defendant recover its cost of action herein; and such other relief as the Court may deem
proper.
Respectfully submitted,
DATED: November 19, 2010
JA 1V M. RETTIG, PABN 200948
418 WILLARD RD
HATBORO, PA 19040
(267) 879-9054
Attorney for Defendant GINGER RILAND
I 4b
VERIFICATION
I, Defendant, GINGER RILAND, verify that the facts set forth in this answer are true and
correct to the best of my knowledge, information, and belief
DATED: 1 Z 0 1 V
Defendant GINGER RILAND
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Pro Credit Solutions
Plaintiff,
V.
Ginger R. Riland,
Defendant,
Docket No. 2010-6693
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o
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE
4009.22
Pro Credit Solutions certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or
delivered to each party at least twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which is attached to the notice of
intent to serve the subpoena.
DATE: January 5, 2011
cl/?o-o'
Thomas L. Maher, Esq.
Attorney for Plaintiff
Pro Credit Solutions
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Pro Credit Solutions,
Plaintiff,
V.
Ginger R. Riland,
Defendant,
Docket No. 2010-6693
NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.21
Pro Credit Solutions intends to serve a subpoena identical to the one that is attached to this notice. You
have twenty (20) days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If no objection is made, the subpoena may be served.
DATE: December 15, 2010
Thomas L. Maher, ESQ.
Pro Credit Solutions
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PCs
File No. 10-6693
Plaintiff
vs.
RILAND
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: (?S 1?a- K-
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: „An,) ad sak docwrKx-a4S 0.5Sl1vic??rcl w;.I-y? 1?,?
040 Kt dQx0 4C"+.
at-fin ('. ? $ott.?y4 o?iS h.0, aex 5-?x 6r,.eeLS lokrA 4 04 f 560 )
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: 7rh)!n[&& L. a&'6?[.j ESQ.
ADDRESS: p b (, L A 58a
TELEPHONE: t- 16 $ S- IJ'_j- 3-,3 S
SUPREMECOURT ID # a o `? O
ATTORNEY FOR: PIo C.rtdil S?turl-.?nS
Dated 12--? -to
Seal of the Court
BY T OURT:
-4 117
ry, tvi Division
Deputy
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Pro cr-C t +- C.-Inloilon5 Plaintiff NO. (0(012 20A_
vs.
Gi t14 Qii latlc?? : c a
Defendant -? 3 -y
CTJ
RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially i =
r n -71
Following form: <> co 69
PETITION FOR APPOINTMENT OF ARBITRATORS a
ca-
TO THE HONORABLE, THE JUDGES OF SAID COURT: ?rn
c 1
J
counsel for th laintiff efendant
7homms Ho? in the above
action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of plaintiff in the action is $ (O. ?3y 3?O
The counterclaim of the defendant in the action is
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit
as arbitrators: TASan h . P..?++? S
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to
whom the case shall be submitted.
?Gf t 7 1)6 11 h,J Respectfully submitted,
ell P,
7/s-
AND NOW,
petition,
Esq., and
ORDER OF COURT
200 , in consideration of the foregoing
Esq., and
Esq., are appointed arbitrators in the above
captioned action (or actions) as prayed for.
By the Court,
Kevin A. Hess, P.J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Pro cn;A-l SC 1,
Plaintiff NO. GG g 3 _ 20AO_
VS.
l CLQ {h i i g. 4 c-)
Defendant C ,,,
cz c
-vim -4
RULE 1312-1 The Petition for Appointment of Arbitrators shall be subst
ti
ll r7l
an
a
y
Following form: tV
rte- x co C) 7
PETITION FOR APPOINTMENT OF ARBITRATORS s -
rt
TO THE HONORABLE, THE JUDGES OF SAID COURT: " N o
_rklo Mq
counsel for th laintiff efendant in --a Cn
v
the above
action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of plaintiff in the action is $ S (p, pay "3Cp
The counterclaim of the defendant in the action is
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit
as arbitrators: J alSan N . Rc}}*t I
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to
whom the case shall be submitted.
aGlO6 1114"i Respectfully submitted,
? I? 7?s3
ORDER OF COURT
AND NOW, 200/ , in consideration of the foregoing
petition,
dl T_ Esq., and
Esq., and Esq., are appointed arbitrators in tlgov
captioned action (or actions) as prayed for. .
cn f-
t
By the Court, x
? Pr-o Cred4 So?u?,?Ks ?, s
A. Hess, P.J.C:: N
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41.1-G
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
PRO CREDIT SOLUTIONS
NO. 10-6693
Plaintiff, :
V. M
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Ma ? oc)
==t
Ginger R. Riland _ c,^
9 D
x'
Defendant
Type of Pleading
PRAECIPE FOR
JUDGEMENT ON AWARD
Filed on behalf of:
Pro Credit Solutions
Plaintiffs
Counsel of Record:
THOMAS L. MAHER, ESQ.
Pa I.D. #207970
PO Box 582
Greensburg, Pennsylvania 15601
(412) 583-3123
0'+w•} } Pd
NOTICE C k-# ?1 t 3
THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND Q a?? (4d
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE
WCL,t ? 4ea
t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
PRO CREDIT SOLUTIONS
NO: 10-6693
Plaintiff,
V.
Ginger R. Riland
Defendant
PRAECIPE FOR JUDGEMENT ON AWARD
To the Prothonotary;
1) On 5/18/11 an award was entered for the Plaintiff in the amount of $10,034.36 plus costs.
2) The defendant has not filed. an appeal
3) Please kindly enter a judgment against the defendant in the amount of $10,034.36 plus
court costs plus attorney's fees in the amount of $500.00.
I hereby certify that an appropriate Notice of Judgment, as attached, has been
mailed in accordance with PA R.C.P. 237.1 on the date indicated on the Notice.
By: J
Thomas L. Maher Esq
ID 4270970
Attorney for Plaintiffs
'Pro Crud f S'ol ons
Plaintiff
G knAn- Rtiaa
1-0 Defendant
In The Court of Common Pleas of Cumberland
County, Pennsylvania No.o_-
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this Commonwealth and that we will discharge the duties of our office
with fidelity.
Signature
K+t lrul k? ?u
Name (Chairman)
`-
Law Firm
690 Q>o IZZ?(
Address
_CA rA tst- 0 1-Ia 13
City, Zip
V U)
Name
Ke?tW -f--A? (*-,- 0 ec
Law Fffm
2-3 3 t
Address
c",
City, Zip
A
St afar
Name
Law Firm
6 o kit R4cge,
Address
C'`iSkGX 1 I70l,9
City, Zip
Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
folloXing award: (Note: If daRpges for delay are awarded, they shall be separately stated.)
r
. Arbitrator, dissents. (Insert name if applicable.)
Date of Hearing: -?- S
(Chairman)
Date of Award:
Notice of Entry of Award
Now, the /9'44day of
ot? , 20 at 9 / ,A M., the above award was
entered upon the docket and notice the of given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $ 350. Dd
\s.h 1EBUFLI By. ?* Mna 0 t-14/1 n F% d%?
Prothonotary Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
PRO CREDIT SOLUTIONS
Plaintiff,
V.
Ginger R. Riland
Defendant
NO: 10-6693
NOTICE OF JUDGMENT OR ORDER
( x ) Notice if hereby given that a JUDGMENT in the above captioned matter has been entered
against you in the amount of $10,034.36, plus court costs plus attorneys fees in the amount of $500.00 , on
2011.
( ) A copy of all documents filed with the Prothonoazzit judgment is/are attached.
By:
If you have an
y questions regarding this Notice, please contact the filing party.
Date: _June 22, 2011 Z- )t-
Thomas L. Maher Esq
ID # 270970
Attorney for Plaintiffs
Pro Credit Solutions
888-793-3238
(This notice is given in accordance with Pa. R.C.P. 236.)
NOTICE SENT TO:
Jason Rettig
100 West Monument Ave
Hatsboro, PA 19040
NOV 2 12011
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
PRO CREDIT SOLUTIONS
Plaintiff,
Vs.
Ginger R. Riland
Defendant(s),
CIVIL DIVISION:
No. 2010-06693
TYPE OF PLEADING:
OAS
INTERROGATORIES
IN ATTACHMENT
FILED BY PLAINTIFF
Attorney Thomas L. Maher, Esq.
Attorney for Plaintiff
Pro Credit Solutions
P.O. Box 582
Greensburg, PA 15601
1-888-793-3238
DATED: November 10, 2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Pro Credit Solutions,
Plaintiff,
Vs.
Ginger R. Riland,
Defendant,
NO. 2010-06693
and
Americhoice FCU
Members 1st FCU
Garnishees,
TO: Members 1st FCU
IMPORTANT NOTICE TO GARNISHEE
A. You are required to file Answers to the following interrogatories within twenty (20) days
after service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "Defendant" means any one or more of the Defendants against whom the
Writ of Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the Defendant
which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee.
For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the
debtor's account, either at the time of service of the Writ or at t: e time of Judgment against the
Garnishee, but rather by the amounts deposited and withdrawn during the intervening period.
D. If any Defendant above named is an individual, has funds on deposit in an account that are
exempt from execution, levy or attachment under Pennsylvania or federal law which are funds deposited
electronically on a recurring bases. If so, identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the entity electronically depositing those funds on
a recurring basis.
E. In your Answers to these Interrogatories in Attachment, please state whether to your
INTERROGATORIES
Description of Defendant(s) for Garnishment:
Please garnish any and all accounts associated with the defendant(s) below:
Ginger R. Riland
SSN: 200-58-4867
Possible Address:
74 Keefer Way
Mechanicsburg, PA 17055
INTERROGATORIES IN ATTACHMENT
1. At the time you were served or at any subsequent time, did you owe the defendant[s] any
money or were you liable to defendant[s] on any negotiable or other written instrument, or did
defendant[s] claim that you owed any money or were liable to defendant[s] for any reason?
V
2_ At the time you were served, or at any subsequent time, was there in your possession, custody
or control of yourself and one or more other persons any property of any nature owned solely or in part
by the Defendant?
I I l?
3. At the time you were served, or at any subsequent time, did you hold legal title to any
property of any nature owned solely or in part by the Defendant held or claimed any interest? If your
answer is "yes", describe the nature, fair market value, and present location of said properties.
no
4. At the time you were served, or at any subsequent time, did you hold as fiduciary any money
or property of any nature in which the Defendant had or claimed interest? If your answer is "yes",
describe the nature, fair market value, and present location of said properties.
5. At any time before or after you were served did the Defendant transfer or deliver any money
or property of any nature to you or to any person or place pursuant to your direction or consent, and if so
what was the consideration therefore? If your answer is "yes", describe the nature, fair market value, and
present location of said properties.
I/1L
6. At any time after you were served did you pay, transfer or deliver any money or property of
any nature to the Defendant or to any other person or place pursuant to this direction or otherwise
discharge any claim of the Defendant against you? If your answer is "yes", describe the nature, fair
market value, and present location of said properties.
()0
7. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which funds are electronically
on a recurring bases and which are identified as being funds that upon deposit are exempt from
execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state
the reason for the exemption, the amount being withheld under each exemption and the entity
electronically depositing those funds on a recurring basis.
8. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not
including any otherwise exempt funds, did not exceed the amount of the general monetary exemption
under 42 Pa. C.S. $ 8123? If so, identify each account.
?, [[tti?cd? cL
Thomas L. Maher, Esq.
Attorney for Plaintiff
PA I.D. 207970
Pro Credit Solutions
VERIFICATION
I verify that the statements made in these Answers to Interrogatories are true and correct.
I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904
relating to unsworn falsification to authorities.
Date: Signature:
f4vl' A
MEMBERS V'
FEDERAL CREDIT UNION
November 21, 2011
Ginger R. Riland
74 Keefer Way
Mechanicsburg, PA 17055
Review Dates (60 Days): September 23, 2011 - November 21, 2011
Total Writ of Execution: $10,231.30
Cumberland County Docket Number: 10-6693
File # 2010-06693
Account Number: XXX896-0000
Name on Account: Ginger R. Riland
Savings: $2,988.81
-5.00 (Membership Fee)
$2,983.81
Account Number: XXX896-0011
Name on Account: Ginger R. Riland
Checking: $50.00
-50.00 (Processing Fee)
$00.00
Payroll: SOC SEC
** The checking account will be unfrozen when Social Security is posted to account**
$300.00 Statutory Exemption was not taken out.
Tania S. Youn
Deposit Operations alyst
Rev: 06/11
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is Ta n is S. Young
(Name)
Deposit Operations Analyst of Members 1st Federal Credit Union
(Title)
(Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
(SIGNATU )
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Pro Credit Solutions, LLC
Plaintiff,
V.
Ginger R. Riland,
Defendant,
and,
Americhoice FCU,
Garnishee,
Docket No. 2010-06693
C') ra CD
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PRAECIPE TO DISCONTINUE AGAINST GARNISHEE(S) ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishee(s), Americhoice FCU and mark the
docket accordingly.
U,--X ???
Thomas Maher
Pro Credit Solutions
aalkk?b?
CIS ??"?
?t? alaq 8?s
IN THE COURT' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
Pro Credit Solutions ,
Plaintiff,
v.
Ginger R. Riland,
Defendant,
Docket No. 2010-06693
PRAECIPE TO SATISFY
TO THE PROTHONOTARY:
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Please mark the above-captioned Judgment as paid and satisfied in full releasing the
defendant from all matters regarding this case.
l
Thomas Maher, Esq.
Attorney for Plaintiff
Pro Credit Solutions
Dated: November 26, 2012
x'9.50 Imo.-A-{~.~
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