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Home My WebLink About12-1122Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie A. Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. p`bt P' I I ? e ( 0 ( ( V. WILLIAM L WOODSIDE 219 W PINE ST MOUNT HOLLY SPRINGS PA 17065 Defendant NOTICE C c? ? s ?r-n 00 m rn__ Uy ?--- ca r- L? N c? M You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty (20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, an 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 of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 00* ?, 7s Q ?(4VD3 e ka-71339 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866428-8102 FAX: 757-518-0860 Attorneys for Plaintiff PRO THON Z?12 FEB 22 ? TAP, M 10: 4 CUN-BERLAun r?...._ ?11140 rtV,NIl 'IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. V. WILLIAM L WOODSIDE 219 W PINE ST MOUNT HOLLY SPRINGS PA 17065 Defendant NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esate contra usted. usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUM UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 I'lis Coll I munication is ?f" orn a debt collec!Or and i? ?zn attempt to C. ; a debt, kn. int6r°rnation obtained ?,N ll be used 10r° that p urlso: e. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: 757-518-0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff No. V. WILLIAM L WOODSIDE 219 W PINE ST MOUNT HOLLY SPRINGS PA 17065 Defendant COMPLAINT Plaintiff, Portfolio Recovery Associates, LLC is a Delaware Limited Liability Company with offices located at 140 Corporate Blvd., Norfolk, VA 23502. 2. Defendant WILLIAM L WOODSIDE, is an adult individual with last known address of 219 W PINE ST, MOUNT HOLLY SPRINGS PA 17065. It is averred that Defendant was indebted to HSBC BANK NEVADA, N.A. / AMERITECH on April 2, 2002 with account number ************8150 (hereafter referred to as "Account"). A copy of the account history is attached here to and collectively marked as Exhibit "A." 4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to the Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. 1 ii'miunic:anoti is l orn a debt collector an6 an attempt to Collect a Jc-ht. kny Mi6miation obtained kill 1-1, ?? i f:)r 111,11 r)Urpos , 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on April 15, 2010. Plaintiff is the purchaser, assignee and/or successor in interest HSBC BANK NEVADA, N.A. / AMERITECH and Plaintiff is now the holder of the Account. A true and correct copy of the affidavit is attached hereto and collectively marked as Exhibit "A." 9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's Account, as a result of Defendant and/or any authorized user's use of said Account is in the sum of $2,787.13. 10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all to the damage and detriment of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, WILLIAM L WOODSIDE, in the amount of $2,787.13, plus costs of this action and any other relief as the Court deems just and reasona e. Robert N. Polas Jr., Esquire # 201259 Carrie A. Brown, Esquire # 94055 11-34765 116s cCzmn-iuniciation is Born a debt coil ami i an attornpt to collect a dcl)te < riv Intorniation obtained krill tic a <-r 1hat pUrposc. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Cristina Patterson hereby states that he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to '006412 Date : 11-34765 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Custodian of Records EXHIBIT A This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, Virginia 23502 Telephone: 1-866-428-8102 Fax: 1-757-518-0860 Statement of Account Account: ************8150 WILLIAM L WOODSIDE Account Holder: WILLIAM L WOODSIDE 219WPINE ST MOUNT HOLLY SPRINGS PA 17065 Consumer Account Product Code: MC Issuer: HSBC BANK NEVADA, N.A. / AMERITECH Assignee: Portfolio Recovery Associates, LLC Account Number: ************8150 Date Account Opened: April 2, 2002 Date of Last Payment: April 15, 2010 Date of Charge Off: November 30, 2010 Balance at Purchase: $2,787.13 Purchase Date: May 23, 2011 Balance at Charge-Off: $2,787.13 Less Payments: $.00 Balance Due: $2,787.13 11-34765 HSBL17 This communication is from a collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, Cllidna Patterson depose, affirm and state as follows: Custodian of Records, for Portfolio Recovery Associates, LLC hereby I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee") which is doing business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia. I am familiar with the policies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's records, including a review of the business records transferred to Account Assignee from HSBC BANK NEVADA, N.A. / AMERITECH ("Account Seller"), which have become a part of and have integrated into Account. Assignee's business records, in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the account, and all proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account having been sold, assigned and transferred by the Account Seller on May 23, 2011. Further, the Account Assignee has been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the settlement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no further interest in said account or the proceeds thereof, for any purpose whatsoever. 4. According to the records transferred to the Account Assignee from Account Seller, and maintained in the ordinary course of business by the Account Assignee, there was due and payable from WILLIAM L WOODSIDE ("Debtor") to the Account Seller the sum of $2,787.13 with the respect to account number (************8150), as of November 30, 2010 with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, Account Assignee claims the sum of $2,787.13 as due and owing as of the date of this affidavit. oPfolio Recovery sso ' es, LLC By: Cdatina on , CustodiaRf c ords Subscribed and sworn to before me on a"`f- of , 2012 Notary Public 11-34765 Dionne Erica LaBoy ` Commonwealth of Virginia Notary Public ,? Commission No. 7512855 My Commission Expires 1213112015 :"11is o r ?s ..xi icaticsn t°c>n? a cleft collector and is an attempt to collect a cleft.. :.?. -n ?jtion obi ?,i c?? ,gill he used for tliat puq) oae° SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson I;"t ,; R; Sheriff Jody S Smith Chief Deputy 21312 FEB 28 AM 8:34 Richard W Stewart CUMBERLAND GO UNITY Solicitor PENNSYLVA/ 1111A Portfolio Recovery Associates, LLC Case Number vs. William L. Woodside 2012-1122 SHERIFF'S RETURN OF SERVICE 02/23/2012 04:19 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2012 at 1619 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William L. Woodside, by making known unto himself personally, at 219 W. Pine Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. UTSHALL, DEPUTY SHERIFF COST: $35.00 February 24, 2012 SO ANSWERS, j?7 RON R ANDERSON, SHERIFF r .;Ci,,n,S!1t ?he?`t IE! -Sofl Irv; William L Woodside c 219 W Pine St MCU zrn z x - r Mt Holly Springs, PA 17065 c > ru 4'1 Cn ?a March 9, 2012 In reference to actions as set forth below: IN THE COURT OF COMMON PLES OF CUMBERLAND COUNTY, PA Cival ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC Robert N Polas Jr. Esquire PA Bar #201259 Carrie A Brown, Esquire PA Bar #94055 140 Corporate Blvd Norfolk, VA 23502 Tele: 1 866 428 8102 FAX: 1 757 518 0860 Attorneys for the Plaintiff VS. William L Woodside 219 W Pine St Mount Holly Springs, PA 17065 Defendant Re: Civil Complaint filed in Cumberland County, PA In the Court of Common Pleas of Cumberland County, PA Your File #2012-1122 Cival Filed - Office of the Prothonotary 2012 Feb 22 10:42 AM To Whom It May Concern: This letter is being sent to you in response to a Cumberland County, PA Sheriff serving me court papers 02/22/2012 at my residence at 219 W Pine t., Mt Holly Springs, PA 17065. Be advised that this is not a refusal to pay, but a notice sent pursuant to the Fair Debt Collection Practices Act, 15 USC 1692g Sec. 809 (b) that your claim is disputed and validation is requested. This is NOT a request for "verification" or proof of my mailing address, but a request for VALIDATION made pursuant to the above named Title and Section. I respectfully request that your offices provide me with competent evidence that I have any legal obligation to pay you. Please provide me with the following: What the money you say I owe is for; Explain and show me how you calculated what you say 1 owe; Provide me with copies of any papers that show I agreed to pay you what you say I owe; Provide a verification or copy of any judgment if applicable; Identify the original creditor; Prove the Statute of Limitations has not expired on this account; Show me that you are licensed to collect in Pennsylvania; Provide me with your license numbers and Registered Agent; At this time, I will also inform you that if your offices have reported invalidated information to any of the three major Credit Bureau's (Equifax, Experian or TransUnion) this action might constitute fraud under both Federal and State Laws. Due to this fact, if your company or the company that you represent finds any negative mark on any of my credit reports I will not hesitate in bringing legal action against you for the following: Violation of the Fair Credit Reporting Act Violation of the Fair Debt Collection Practices Act Defamation of Character If your offices are able to provide the proper documentation as requested in the following Declaration, I will require at least 30 days investigating this information and during such time, all collection activity must cease and desist. Also during this validation period, if any action is taken which could be considered detrimental to any of my credit reports, I will consult with my legal counsel for suit. This includes listing any information to a credit-reporting repository that could be inaccurate or invalidated or verifying an account as accurate when in fact there is no provided proof that it is. If your offices fail to respond to this validation request within 30 days from the date of your receipt, all references to this account must be deleted and completely removed from my credit file and a copy of such deletion request shall be sent to me immediately. I would also like to request, in writing, that no telephone contact be made by your offices to my home or to my place of employment. If your offices attempt telephone communication with me, including but not limited to computer generated calls and calls or correspondence sent to or with any third parties, it will be considered harassment and I will have no choice but to file suit. All future communications with me MUST be done in writing and sent to the address noted in this letter by USPS. It would be advisable that you assure that your records are in order before I am forced to take legal action. This is an attempt to correct your records; any information obtained shall be used for that purpose. Best Regards, William L Woodside Cc: File Cumberland County, PA Court of Common Pleas, Civil Division Portfolio Recovery Associates, LLC Carrie A. Brown, Esquire PA Bar #:94055 Robert N. Polas, Jr, Esquire PA Bar #: 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk; VA 23502 TELE: 1-866-428-4102 FAX: 757-518-0860 Attorneys for Plaintiff f iI i ;JiLC"OTARY I.`-'?,FR, AND COUNTY IN THE COURT OF COMMON FILES OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC : Plaintiff No. 2012-1122 V. WILLIAM L. WOODSIDE Defendant PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Plaintiff demands that Defendant 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 Defendant answer and respond to the following Request for Admissions pursuant to Pa. Rule 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. 6. 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. 7. 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. The word "documents(s)" means all written, printed, recorded, graphic, or photographic matter, or, sound reproductions, however produced or reproduced, pertaining to any 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 dated, 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 possession, custody, or control, or in existence, state the date and manner of its disposition; and E. The word "identify", when used with respect to an act (including an alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act"), means to (1) described the substance of the event or events constituting such an act, and to state the date when such an act occurred; (2) identify each and every person(s) participating in such an act; (3) identify all other 12erson(s) (if any) present when such an 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. S. Unless otherwise indicated, all Requests herein relate to those certain 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 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 file it was produced and all current custodian of said document. If a document called for it 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. If any document called for by this request is withheld on the basis of any claims of privilege or any similar claim, identify that document as follows: author, addressee; indicated or blind copies, dated, 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 and/or provide testimony on as evidence at the time of the trial. REQUEST FOR ADMISSION NO. 1: Defendant applied for the Credit Card referenced in the Complaint. Admitted Denied If the answer to Request for Admissions No. 1 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 2: Defendant has failed to make all required payments on the credit card. Admitted Denied If the answer to Request for Admissions No. 2 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 3: The attached monthly statement correctly identifies the balance on the account. Admitted Denied If the answer to Request for Admissions No. 3 is "denied", then supply copies of canceled checks, both front and back, and/or if not available, specific written documentation supporting the denial.. REQUEST FOR ADMISSION NO. 4: Defendant has not submitted any written dispute as to the billing inaccuracy concerning the credit card in question during the time the account was opened on April 2, 2002 until the last payment date of April 15, 2010. Admitted Denied If the answer to the Request for Admissions No. 4 is "denied", then supply copies of specific written disputes as to any billing inaccuracies REQUEST FOR ADMISSION NO. 5: $2,787.13 is the correct and accurate balance of the credit card account in question at the time the account was charged off. Admitted Denied If the answer to Request for Admissions No. 5 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. RE VEST FOR ADMISSION NO. 6: 6. Please admit that you agreed to pay Plaintiff's predecessor all amounts due resulting from the use of your credit card account, including any finance charges and other charges due under the terms of the agreement. Admitted Denied If the answer to Request for Admissions No. 6 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. RE OEST FOR ADMISSION NO. 7: 7. Please admit that for each month you had a balance on your credit card account, you were sent, by mail or otherwise, a bill, statement of account, invoice or other request for payment showing all transactions billed to your account during the billing period. Admitted Denied If the answer to Request for Admissions No. 6 is "denied", then supply specific written documentation supporting the denial and indicate with full explanation what you believe to be the correct balance on the account. INTERROGATORIES 1. Please identify the person(s) answering these Interrogatories. ANS ER: 2. Please identify each and every person that has assisted you in responding to these Interrogatories. ER: ANS 3. Separately, for each of your answers to Requests for Admissions 1 through 9 above where your answer is anything other than an unqualified admit, please: a. State each fact known to you upon which you rely to support your denial or qualified answer; b. If your response is that you do not have sufficient information or knowledge to admit or deny, then describe each effort you have made to acquire the information you feel would be necessary to admit or deny the request; C. Identify each document known to you which you believe contains information relevant to your answer; and ANSWER: 4. d. Identify each witness known to you who may have knowledge with respect to the information upon which you rely for your denial or qualified answer and as to each witness, state the information you believe is known to them with respect to your answer. If you filed affirmative defenses to Plaintiffs Complaint, separately for each defense, please: a. State the factual basis that supports your defense; b. Identify each document known to you which you believe contains information relevant to your defense; and C. Identify each witness known to you who may have knowledge with respect to the information upon which you rely for your defense and as to each witness, please state the information you believe is known to them with respect to your defense. ANS ER: 5. Have you ever requested Plaintiff's predecessor to open a credit card account in your name? If so, please state the credit card account number(s). ANSWER: 6. Are you aware of any credit card accounts with Plaintiff's predecessor opened in your name? If so, please state the credit card account ANSWER: number(s). 7. Have you ever made a purchase or obtained a cash advance by using a card, account number and/or account access check issued by Plaintiff's predecessor? If so, please state the credit card account number(s) and the date(s) of the purchase or cash advance. ANSWER: 8. Has Plaintiff's predecessor ever sent to you, by mail or otherwise, any bills, statements of account, invoices or other requests for payment? If so, identify each document and state whether you objected to it. If you have objected, identify each objection, including whether it was written or oral. ANS ER: 9. Have you ever objected, in writing or otherwise, to any bills, statements of accounts or invoices you were sent? ANSWER: 10. If you keep records of purchases or payments with respect to your credit card account with Plaintiff's predecessor, do these records show a balance owing on the account? If so, what is that balance? ANS ER: 11. Is there any portion of Plaintiffs claim that you admit you owe? If so, state the amount that you admit you owe to Plaintiff and any facts that support your claim that you do not owe the rest of Plaintiff's claim. ANS3YER: 12. If you claim that the account on which Plaintiff is suing is inaccurate, specify each inaccuracy and any facts that support your conclusion that the account is inaccurate. ANS ER: Respectfully Sub ' d, By: ( ---, 7 Carrie A. Brown, Esquire #94055 Robert N. Polas Jr., Esquire #201259 Carrie A. Brown, Esquire PA Bar #:94055 Robert N. Polas, Jr, Esquire PA Bar #: 201259 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk'', VA 23502 TELE: 1-866-428-4102 FAX: 7§7-518-0860 Attorn vs for Plaintiff THE COURT OF COMMON PLES OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff No. 2012-1122 V. WILLIAM L. WOODSIDE Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Request for Admissions upon Defendant, by First Class Mail, Postage Pre-Paid, a copy thereof on this ) ! day of , 2012, to: William L. Woodside 219 W Pine Street Mount Holly Springs, PA 17 By: Carrie A. Brown, Esquire #94055 Robert N. Polas Jr., Esquire #201259 ` 0 'SL T.C r 1 DANK GOLD MASTERCARD Household Bank Gold MasterCard Account Statement Account Number IIIM?-8 t50 _ _--______ Page 1 of 2 From October 26, 2010 to November 25, 2010 Previous Balance $2,721.33 Payinents - 50.00 Other Cred_ts - $0.00 PurchaseslDebils + $0.00 Balance rumsfers + 50.00 Cash Advances + 50.00 Past Due A.nount $598.00 Fees Charged + $0.00 Interest Charged_ + $65.80 New Batarce $2,737.13 Credit Limit $2,200.00 Credit Available 50.00 Statement Closing Date November 25, 2010 Days in Bif ing Cycle 30 imp New Balance $2,787.13 I Minintum Payment Due $692.00 1 j Payment Due Date December 20, 2010 1 { I Late Payment Warning: If we do not receive your minimum payment by the j date listed above, you may have to pay a late fee of up to $35.00 and your APRs may be increased to the Penalty APR of 29.99%. E Minimum Payment Warning:If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your I balance. For example: 1 j 1 i you this statement in i and each month I 1 only die minimum 17 ... Years ? $7,329 i j i $ { 17 3 Years $4,209 3 I ? I f If you would like information about credit counseling services call 1-866-569-2227. if you make no additional You will pay off the ; And you will end up paying charges using this card balance shown on f an estimated total of.- pay-.. about Payment 1 (Savings = 83,120) f Questions? Payment Address: HSBC Card Services, PO Box 17051, Baltimore. MD 24HourCustomer Service 1-800-477-6000 21297-1051 Lost or Stolen Card E-800-3954500 Billing Inquiries: HSBC Card Services, PO Box 81622, Salinas, CA Outside USA Collect 1-757-523-3880 93912-1622 TDDlHearing Impaired 1-800-395-9020 Manage Your account online at www.householdbank.eom As a reminder, you may pay your credit card bill online or through our automated phone system for no fee. IF YOU ARE UNABLE TO SEND YOUR PAYMENT TODAY, PLEASE CALL 800-395-0500 TO DISCUSS A REPAYMENT ARRANGEMENT. Trans Date Post Date Description of Fees INTEREST CHARGE ON BALANCE Description of Interest Charge INTEREST CHARGE ON CASH ADVANCES INTEREST CHARGE ON PURCHASES TRANSFERS Total Interest For This Period I Total fees charged in 2010 S160.00 Detach and arum botam wifiai mth ymv pay-n. Total interest charged in 2010 5594.13 Reference Number Amount $61.15 $0.00 Amount 54.65 $65.80 090550 5 E LS OOOOOOOID3 6 S1MI'08 D 9 28893 HDPI 500 reverse side for inpOttant infomleDOn Account Number: ??•8150 New Balance $2,787.13 Minimum Payment Due $692.00 Payment Due Date 12!20/2010 Include account muntxr on check to HSBC Card Services. Do not send cash. Please send your payment 7 to 10 days prior to the payment dire date to ensure timely delivery. 090 AMOUNT ENCLOSED HSBC CARD SERVICES WILLIAM L WOODSIDE PO BOX 17051 219 W PINE ST BALTIMORE MD 21297-1051 MOUNT HOLLY SPRINGS PA 170651123 IIIIIII?IIIIIIIIIIIIIIIIIIIIII'IIIIIIIIIIIIIIIIIIiIItIIIIIIItIIII ???'I'I'IIPIIIIIIIIII?I????tllNllplndll?6?lllll?61d?6p? 'AALIAAI `V *DSIJ}- Household Bank Gold Master Car Account Statement Account Number 8[50 Page 2of2 From October 26, 2010 toNovem erg ,2010 Your Annual Percentage Rate (APR) is the armml hLterest r ite on your acconut. Type of Balance Annual Percentage Ra:e (APR) Balance Subject to Interest Rate Interest Charge CASH ADVANCES 20001 28.99°'S (v) SM79 $1 45 PURCHASES I(,Oi)1 28.9991 (v) $2,444.06 $58.24 CASHADVANCES 20001 29.999, (v) $129.96 $3.20 PURCHASES NOW 29.99%i (v) $118.19 $2.91 BADWCE TRANSFER 29.99%i (v) $0.00 $0.00 41111 v=variable Rate Online Aceoumt Access lets you take control of your Account anytime, anywhere. Registration is easy, secure and waiting for you at go.householdbank.com. 090550 5 5 25 0000000103 G MOW V 4 28893 HDPI HOUSEHOLD BANK GOLD WILLIAM L WOODSIDE -Valued Cardmember Since 2002 ACCOUNT SUMMARY ACCOUNT 8150 NUMBER TOTAL CREDIT LIMIT 52:200 TOTAL CREDIT LIMIT S() AVAILABLE STATEMENT DATE 12123109 PAYMENT SUMMARY MINIMUM PAYMENT` 576.00 PAYMENT DUE DATE 01117110 OVERLIMITAMOUNT 555.26 CURRENT PAYMENT DUE' $131.28: To avoid an overlimit fee on yam New Belonce, you must pay the Current PaymenrDue (which rnchrda the ATmdmum Payment and any Orerlimir Amount). ^ See About Your Paymen on reverse for an explanation of these amounts. 4 s? c Iof2 BALANCE SUMMA Y PREVIOUS BALANCE 0. 79 PAYMENTS/CREDITS - 4.00 PURCHASESIDEBITS r ?4.93 FINANCE CHARGE + 32_54 NEW BALANCE TRANSACTION SUMMARY (For additional transaction detail go to www+housetioldbank.com) TRANS PST TRANSACTION REFERENCE AM DATE D TE DESCRIPTION NUMBER CHARGES 11/25 11125 PAYMENT-THANK YOU 6540801932901VW537V5VG3 11125 111/25 PAYMENT-THANK YOU 65408019329012PVGPJYMBP 11130 11130 PAYMENT-THANK YOU 6540801933401VH9RV8DSSL 12108 12108 PAYMENT-THANK YOU 6540801934201S6LGLP84PG 11127 1127 EXPEDIA"TRAVEL 800-367-3476 NV MT093310101D00010005096 $120.24 11126 11128 UNITED ATLANTA GA MT093320104000010031013 $32150 1127 11130 METABANK Carlisle PA MT09334010200001OD93885 $102.00 12103 17104 Flying J G store outsi Millersport OH MT093380105000010010818 $24.50 12/03 1405 ULTRON, INC WHEELING WV MT093$90102000010005884 $143.00 12/09 17110 CHARLEYS STEAKHOUS ORLANDO FL MT093440113000010034199 $44.99 12112 17114 PAYLESSIAMERICAR/RAINBORLANDO FL MT093480104000010009800 $139.24 12/13 1115 SARAH CPS MIDDLETOWN PA MT093490106000010005848 $71,98 12117 12,118 SHEETZ 00002QPS MT HOLLY SPRG PA MT093520107000010015812 $4.98 12/21 141722 PNC BANK MT HOLLY SPN PA MT093560104000010024049 $22.50 11/30 11130 CASH ADVANCE FEE 10000001030000999874770 510.00 12105 1 708 CASH ADVANCE FEE 10000001030000999724160 $1000 12122 12122 CASH ADVANCE FEE 100000010300009997995W 510.00 C -D 9 -S 0.00 -S 0.00 -S 9.00 -S f 5.00 ? ML PAYMENTS TO: HSBC CAR SERVICES PO Box oo BALTIMOR MD 21288-0001 2 QUESTIONS? 24-HOUR CUSTOMER SERVICE 1-800-477.6000 OUTSIDE USA, COLLECT: 1-757.523-38W TDD HEARING IMPAIRED. 1-8W-395-9020 .61 Manage your account online at: www household bank corn H MAIL INQUIRIES' 0: HSBC CARD SERVICES PO BOX 81622 SALINAS CA 93912-1822 HOP1 0905505 73 0000000103 G SfMT11 D 4 00010111 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On wr . ieck Account Number 816C 4ew Balance $2,255.26 Minimum Payment 676.0( °ayment Due Date 01/17/10 Current Payment Due _ $131.211 lclude account number on check to HSBC CARD SERVICES. Do not send cash. Se d I aymer 7 to 10 days prior to Payment Due Date to ensure timely delivery. To avoid an ove:I imi', fee on your New Balance, pay the Current Payment Due. Amount Enclosed WILLIAM L WOODSIDE 219 V? PINE ST MOUNT HOLLY SPRINGS PA 170651-1123 ir?luhril?irirlll?ri??hrirll?ririlniudlil?nlurunili?ii lrihhll?nri?rrrnlrn?rllrr?ulnrl???liilrin?li? ?irlrliirii HSBC CARD SERVICES PO BOX 8Boo0 BALTIMORE MD 21288-0001 HOUSEHOLD BANK GOLD WILLIAM L WOODSIDE - Valued Cardmember Since 2002 Iof2 FINANCE CHARGE CALCULATION This is a grace account Grace period information on back. Average Daily Days FINANCE CHARGE Nominal WAL Daily Periodic in At Periodic Cash Advance/ Annual Pt_ CF 'AGE Balance Rate Billing Rate Transaction Fees Percentage WE Cycle Rate CASH ADVANCES $213.08 0.08217%(v) 30 $5.25 $30.00 29.99%(v) 1 131% PURCHASES $1,918.18 0.08217") 30 $47.29 $0.00 29.99%(v) J90% (v) indicatesvariable rate IMPORTANT INFORMATION TDDIHe rin impaired: 1-800-655-9392. **********CARDMEMBER NEWS********** Online Account Access lets you take control of your Account anytime, anywhere. Registration is easy, secure and w aitir for you at go.householdbank.com. ? MAIL PAYMENTS TO: HSBC CAR SERVICES PO BOX BAL11MOR MD 21288.0001 It QUESTIONS? 24-HOUR CUSTOMER SERVICE i-SW-477-e000 OUTSIDE USA, COLLECT: 1-757-523-3880 TDD HEARING IMPAIRED: 1-800-395-9020 Ja Manage your account online at: www. householdba n k. co m i9 MAIL INQUIRIES 11:): HSBC CARD SERVICES PO BOX 81822 SALINAS CA 93912-1822 0905505 P3 0000000103 G S1MTI1 D 4 00010111 HOPI PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On Your i Beck 4 !fir 11 11, ;HVi U 1:4ANV, (A-U.) MASJ. RCARD 'hILLIANI L WOODSIDE - Valued Cardmember Since 2002 Payments - $250.00 Other Credits - $0.00 Purchases/Debits + $140.00 Balance Transfers + $0.00 Cash Advances + $140.00 Past Due Amount $0.00 Fees Changed + $20.00 Interest Charmed + $52.47 Credit Limit $2,200.00 Credit Available $0.00 Statement C!Iosing Date April 25, 2010 Days in Billing Cycle 30 Household Bank Gold MasterCard Account Statement Account Number 8150 of 2 From March 26, 2010 to April 5, 2010 New Ii:l Ial .r $2,250.08 Mhnhn un ' ymeut Due $75.00 Payin, ! ". ,, Date May 20, 2010 Late P.lyl iiu t Warning: If we do not receive your mini aril payment by the date li,,cd ibove, you may have to pay a $35.00 late fee and your APRs may be inci-st;i to the Penalty APR of 29.99%, Minimum Payment Warning:If you make only die minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: If you make no additional You will pay off the i And you will end up paying charges using this card balance shown on an estimated total of... and each month you this statement in pay... about... Only the minimum 18 Years 1$7.031 Payment $96 3 Years I S3,438 i (Swings = 83,393) If you would like information about credit counseling services call 1-866-569-2227. Questions? Payment Address: HSBC Card Services, PO Box 88000, Baltimore, MD 24-Hour Customer Service 1-800477-60W 21288-0001 Lost or Stolen Card 1-800.3954500 Billing Inquiries: HSBC Card Services, PO Box 81622, Salinas; CA Outside USA Collect 1-757-523-3880 93912-1622 TDD/Hearing Impaired 1-800-395-9020 Manage Your account online at www.housoholdbank.com Notwithstanding the 'Annual Percentage Rate' disclosure on the reverse, if your Account has a variable rate, the prime rate used In the calculation of the variable APR Is the U.S. Prime Rate published in the Money Rates table of The Wall Street Journal that is in effect on the last day of the month ("Prime Rate"). If the Prime Rate changes, the new APRs will take effect on the first day of your billing cycle beginning in the next month. As a reminder, you may pay your credit card bill online or through our automated phone system for no fee. Your account is over the credit limit. Please pay your total due of $125.08, which includes any additional over the credit limit almomu and your Minimum Payment Due, minus any Past Due amount Trans Date Post Date Descdptlon of Transaction or Credit Reference Number Amount 04105/10 04/06/10 PAYMENT-THANK YOU 6540801009501KXM1WF3SNV 4175.00 04115/10 04116/10 PAYMENT-THANK YOU 6540801010501DCFTZW7CID -$75.00 Total Payment For This Period -$250.00 Trans D$te Post Date Description of Transaction or Credit Purchase Type Reference Number Amount 04/15/10 04117/10 M&TBANK MT HOLLY SPR PA MT101070102000010025212 $40.00 04120/10 04/22110 M&TBANK MT HOLLY SPR PA MT101120€01000010020265 $100.00 Total Purchases For This Period $140.00 Trans Date Post Date Description of Fees Reference Number Amount Detach and ceuun bolt= po im wall yae pay-t. 0905505 25 0000000103 0 ST&Ml D47177 rmPJ See reverse side for lmponent infomtetion -------------------------------------------------------------------------------------------------------------------------------------. Account Number: iOMMM011OW8150 New Balance $2,250.08 Minimum Payment Due $75.00 Payment Due Date 0512012010 Include account number on check to HSBC Card Services. Do not send cash. Please send your payment 7 to 10 days prior to the payment due date to ensure timely delivery. 090 AMOUNT ENCLOSED HSBC CARD SERVICES WILLIAM L WOODSIDE PO BOX 88000 219 W PINE ST BALTIMORE MO 21288-0001 MOUNT HOLLY SPRINGS PA 170851123 i16d16Plhii?ih?u1141iUbilh?idllthhitilitllll416?1 r-rt tl,' N. ,H.U!,)J 'JHIV k ""Lu 1V1H.;?i 1 ?1C1 A iCU WILLIAM L WOODSIDE - Valued Cardmetnber Since 2002 Household Bank Gold MasterCard Account Statement Account Number ?8150 of 2 From March 26, 2010 to April 25, 2010 04/17/10 04118/10 CASH ADVANCE FEE 10000001030000999904440 $10.00 04122/10 04/22/10 CASH ADVANCE FEE 10000001030000999844880 $10.00 II?? NN?ff aa uu Total Fees For This Period $20.00 Description of Interest Charge Amount INTEREST CHARGE ON CASH ADVANCES $2.44 INTEREST CHARGE ON PURCHASES $50.03 INTEREST CHARGE ON BALANCE $0.00 TRANSFERS Total Interest For This Period $52.47 1. Total fees charged hl 2010 $55.00 Total interest charged in 2010 $162.08 I d Your Ann al Percentage Rate (APR) is the annual interest rate on your account. i Type of B lance Annual Percentage Rate (APR) Balance S jb : -t to Interest Rate Interest Charge CASH ADVANCES 20001 28.99% (v) ;1.14 $L93 PURCHASES 10001 28.99% (v) $' .)99.66 $50.03 CASH ADVANCES 20001 28.99% (v) ; a37 $0.51 BALANCE TRANSFER 28.99% (v) 10.00 $0.00 41111 v=[unable Rate To learn about services we offer to protect your account at times of need, visit www.personalaccowdpl vection.com to enroll today. 0905505 25 0000000103 0 S7M771 D 4' 177HDP1 r7.VUJ I7.V)?Ll .Dt11V11lJVLLJ 1V1tiJ161?1.t1AL ,fir WILLIAM L WOODSIDE f; Previous Balance Payments Other Credits Purchases/Debits Balance Transfers Cash Advauces Past Due Amount Fees Charged Credit Limit Credit Available Statement Closing Date Days in Billing Cycle $0.00 $0.00 $38.30 $0.00 $0.00 $77.00 $35.00 $54.73 $2,287.61 $2,200.00 $0.00 March 26, 2010 31 Household Bank Gold MasterCard Account Statement Account Number ?iiiiiiliilgl!i() of 2 From February 23, 2010 to March 26, 2010 F til? . eI New - I $2,287.61 Minis i I pneinDue $155.00 Paym i Date April 20, 2010 1 Late I i m i rut Warning: If we do not receive your aut unum payment by the date li e Bove, you may have to pay a $35.00 late fee and your APRs may f be utc i e i :o the Penalty APR of 29.99%. i Minim nr Payment Warning: If you make only die minimum payment each 1 period v: u will pay more fit interest and it will take you longer to pay off your balance. 'arexample: l If yon male no additional You will pay off the And you will end up paying chart: s using this card balance shown on an estmiated total of... and t? c i month you this statement in '., pay.. about... f i Only i liu minimum 17 Years $6,793 Payni, i t - - ----------- - $96 3 Years j $3,451 (Savings = $3,342) 1 If you would like information about credit counseling services call 1-866-6E9-2227. E-- Questions? Payment Address: HSBC Card Services, PO Box 17051, Baltimore. MD 24-Hour Customer Service 1-800477-6900 21297 -1051 Lost or Stollen Card 1-800-395-4500 Billing Inquiries: HSBC Card Services, PO Box 81622, Salinas. CA Outside USlACollect 1-757-523-3880 93912-1622 TDD/Hearing Impaired 1-800-395-9020 Manage Your account online at www.householdbank.com You have' triggered the Penalty APR of 29.99%. This APR will vary with the market based on the Prime Rate. This change will impact your account as follows: Transactions made on or after 04/15/2010 _ As of 05/27/2010, the Penalty .APR will apply to these transactions. We may keep the APR at this level indefinitely. Transaeions made before 04/15/2010 : Current rates will continue to apply to these transactions. However, if you become more than 60 days late on your account, the Penalty APR will apply to those transactions as well. As a reminder, you may pay your credit card bill online or through our automated phone system for no fee. Your account is over the credit limit. Please pay your total due of $165.61, which includes your Minimum Payment Due and any additional over the credit limit amount. PROTECT YOUR CREDIT RATING. YOUR ACCOUNT IS PAST DUE. CALL 800-395-0500 TODAY TO MAKE YOUR PAYMENT. THANK YOU. I Trans Date Post Date Description of Transaction or Credit Purchase Type 03/02/10 03/03110 SHEETZ 00002329 MT HOLLY SPRG PA 03/03/10 03104/10 SHEETZ 00002QPS MT HOLLY SPRG PA Dekch and tarns bot porsoo wilh your payarml. 09055D 5A 25 0000000103 O SrMrtl D 4 17256 HDP1 Reference Number Amount MT100620104000010013020 $10.00 MT 100630105000010012418 $13.85 See reverse side for important ofarn sm Account Number: 8150 New Balance $2,287.61 Minimum Payment Due $155.00 Payment Due Date 04/20/2010 Include account number on check to HSBC Card Services. Do not send cash. Please send your payment 7 to 10 days prior to the payment due date to ensure timely delivery. 090 AMOUNT ENCLOSED HSBC CARD SERVICES WILLIAM L WOODSIDE PO BOX 17051 219 W PINE ST BALTIMORE MD 21297-1051 MOUNT HOLLY SPRINGS PA 17065-1123 ---- 11111-1-11.IIIIIII....II..I....I..I.I.I..II..IIII.I.i IIII?I?'l1III?I1?????II???I?IIII?II II I?I?I?I?I?IIIIIIII I???II ?? ^.V''O. ?t11 Jl nH!vt\VVlll1V1ANa.tSKCA.Kll WILLIAM L WOODSIDE Household Bank Gold MasterCard Account Statement ACCountNumber5?B150 y,. of 2 17roln February 23. 2010 to Marclt 26, 2010 03/05/10 03/06/10 SHEETZ 00002QPS MT HOLLY SPRG MT 10065010' 30000 10012886 $11.66 PA 03106/10 03/08110 PRETZEL PLUS CARLISLE PA n4TI00670101000010145032 $2.79 Total Purchases For This Period $38.30 mmm II NN g Trans Date Post Date Description of Fees Reference Number Amount 03/20/10 03/20/10 LATE CHARGE ASSESSMENT 10000001030000999903970 $35.00 Total Fees For This Period $35.00 II qq Y Description of Interest Charge Amount INTEREST CHARGE ON CASH ADVANCES $4.63 INTEREST CHARGE ON PURCHASES $50.10 INTEREST CHARGE ON BALANCE $0,00 TRANSFERS Total Interest For This Period $54.73 Total fees charged n 2010 $35.00 Total interest charged in 2010 $109.61 Your Annual Percentage Rate (APR) is the annual interest rate on your account. Type of Balance Annual Percentage Rate (APR) Balance Subject to Interest Rate Interest Charge CASH ADVANCES 20001 28.99% (v) $187.91 $4.63 PURCHASES 10001 :!8.99% (v) $2,034.73 $50.10 BALANCE TRANSFER 28.99% (v) $0.00 $0.00 41111 v=Variable Rate Interested is finding out more about our Over the Credit Limit Coverage? Go on-line or call the number on the back of your credit card for more information. Online Account Access lets you take control of your Account anytime, anywhere. Registration is easy, secure and waiting for you at go.householdbank.corl. To team about services we offer to protect your account at times of need, visit www.pemnalaccountprotection.com to enroll today. 090550 5 A 15 0008080103 G STMnl D 4 17286 HDPI ______________________________________ -------------------------------- '.4 ILLIANI l_ WOODSIDE -Valued Cardmember Since 2002 Household Bank Gold MasterCard Account Statement Account Number 541110MOM -8150 , l of 2 From January24, 2010 to February 23, 2010 Previous Balance $2,272.20 Payments - $260.00 Other Credits - $0.00 Purchases/Debits + $82.50 Balance'Trimsfers + $0.00 Cash Advances + $82.50 Past Due Amount $0.00 Fees Charged + $10.00 Interest Charted + $54.88 Credit Limit $2,200.00 Credit Available $40.42 Statement Closing Date February 23, 2010 Days in Biting Cycle 30 New Balance $2,159.58 Minimum Payment Due $77.00 Payment Due Date March 20, 2010 Late Payment Warning: If we do not receive your miniinum payment by the 1 date listed above, you may have to pay a $35.00 late fee a11d your APRs may be inacased to die Penalty APR of 29.99%. i Minimum Payment Warning: Ifyou make only die minimum payment each j period, you will pay more in interest and it will take you longer to pay offyour j balance. For example: j I If you make no additional You will pay off the ` And you will end up charges using this card balance shown on paying an estimated and each month you this statement in total of... pay... about... Only the minimum 17 Years `$6,706 Payment $92 3 Years j $3,300 i (Savings = j $3,406) If you would like information about credit counseling services call 1-866-569-2227. Questions? Payment Address: HSBC Card Services, PO Box 88000, Baltimore, MD 24-Hour Customer Service 1-800-477-6000 21288 -0001 Lost or Stolen Card 1-800-395-4500 Billing Inquiries: HSBC Card Services, PO Box 81622, Salinas, CA Outside USA Collect 1-757-523-3880 93912 -1622 TDD/Hearing Impaired 1-800-395-9020 Manage Your account online at www.householdbank.com As a reminder, you may pay your credit card bill online or through our automated phone system for no fee Trans Date Post Date Description of Transaction or Credit 02109/10 02/09/10 PAYMENT -'ITIANK YOU 02/19110 02119/10 PAYMENT-THANK YOU Total Payment For This Period Trans Data Post Date Description of Transaction or Credit 02/L6/10 02118/10 PNC BANK MT HOLLY SPN PA Total Purchases For This Period Trans Date Post Date Description of Fees 02/18110 02118/10 CASH ADVANCE FEE Total Fees For This Period Description of Interest Charge Amount Detmh wd cetm Wit-patim with your py-d. 0905505 25 0000000103 D SrM111 D46380!DPI See reverse side for wo"ni Wconation -----------------_-----__-------_-_---.-_-_-_---__----_---------__---_----__----__--_-___-_--------_-----_---__-_--_---_--------__----. Account Number: 8150 New Balance $2,159.58 Minimum Payment Due $77.00 Payment Due Date 03/20/2010 Include account number on check to HSBC Card Services. Do not send cash. Please send your payment 7 to IO days prior to the payment due date to ensure timely delivery. 090 AMOUNT ENCLOSED Reference Number Amount 6540801004001DW2C7LO58D -$160.00 6540801005001VPQP3KX019 4100.00 -$260.00 Purchase Type Reference Number Amount MT100490105000010018447 $82.50 $82.50 Reference Number Amount 10000001030000999793870 510.00 $10.00 HSBC CARD SERVICES WILLIAM L WOODSIDE PO BOX 88000 219 W PINE ST BALTIMORE MD 21288-0001 MOUNT HOLLY SPRINGS PA 1706-1-1123 II'IIII???I?II?II?IIIII'I'II?III?IIIII??IIII'III??II?Iltlll?l?lll I?I??II'lII1??lII?IIII??I?III?lnl?lllll?f ??IIIIIII?IIII?'I?II?II !_iAN-K (JOLD MASTERCARD W7LLIANI L WOODSIDE - Valued Cardtnember Since 2002 Household Flank Gold MasterCard Account Statement Account Number 5? ISO of 2 From January 24, 2010 to February 23, 2010 INTEREST CHARGE ON CASH ADVANCES $6.20 INTEREST CHARGE ON PURCHASES $48.68 INTEREST CHARGE ON BALANCE $0.00 $54.88 Your Annual Percentage Rate (APR) is the annual interest rate on your account Type of Balance Annual Percentage Rate (APR) Balance S.Iblect to Interest Rate Interest Charge CASH ADVANCES 20001 29.99% (v) $_51.65 $6.20 PURCHASES 10001 '7.9.99% (v) $1.974.74 $48.68 BALANCE TRANSFER 29.99% (v) 50.00 $0.00 41111 v=Variable Rate FIRST MONTH FREE! NETZERO INTERNET ACCESS-Theft Plates As Low As $9.95/month! CALL. 1-866-NetZero and Mention promo code A34477 OR go to www.866N0Zero.com/AE4968 NO credit card required. Great Features: Easy Online Sign-up Proc,ss. Spam and Email V inls Protection. Nationwide. Reliable Access. Toll-Free Service Available. NETZERO INTERNET ACCESS. 0905505 25 0000000103 0 STWMI D 4 638OHDPI HOUSEHOLD BANK GOLD WILLIAM L WOODSIDE - Valued Cardrnember Since 2002 7 of 2 5.26 3.00 8.94 ACCOUNT SUMMARY ACCOUNT VPMVMMMW-8150 NUMBER TOTAL CREDIT LIMIT $2,200 TOTAL CREDIT LIMIT $0 AVAILABLE DATE 0112411(] PAYMENT SUMMARY MINIMUM PAYMENT' $82.00 PAYMENT DUE DATE 02118110 OVERLIMITAMOUNT $72.20 CURRENT PAYMENT DUE- $154.20 To avoid an owhmitfee on ymff Nev Bolance, you must pay the Cur entPaymrent Due (which includes the Mudmum Payment and any overiimir amount). " See About Your Paymen on reverse for an explanation of these TRANSACTION SUMMARY (For additional transaction detail go to www.householdbank.com) TRANS POST TRANSACTION REFERENCE DATE D E DESCRIPTION NUMBER 01/08 0108 PAYMENT-THANK YOU 6540801000801V31CMOZJ3Z 01114 011115 M&T BANK MT HOLLY SPR PA MT1 001 501 0400001001 553 4 01115 0118 M&T BANK MOU NT HOLLY PA MT1 001 801 01 000010064 930 01115 OV15 CASH ADVANCE FEE 10000001030000999833120 01118 01118 CASH ADVANCE FEE 10000001030000999800300 AMOUNT CHARGES C ED- Si.00 S40.00 533.00 $10.00 S1000 FINANCE CHARGE CALCULATION This is a grace accounL Grace period information on back. CASH ADVANCES PURCHASE$$ (v) indicates variable rate Average Daily Days Daily Periodic in Balance Rate Billing Cycle $288.96 0.08217%(v) 32 $1,972.55 0.08217%(v) 32 FINANCE CHARGE Nominal At Periodic Cash Advance/ Annual Rate Transaction Fees Percentage Rate $7.07 520.00 29.99%(v) $5187 $0.00 29.99%(v) t NUAL P tCl t TAGE IRATE 1 ( 776% c 990% ? MAIL PAYMENTS TO: i$r QUESTIONS? t @ MAIL INQUIRIES 0: HSBC CAR SERVICES 24-HOUR CUSTOMER SERVICE HSBC CARD SERVICES PO BOX 88 1-800.477-6000 PO BOX 81622 BALTIMORE MO 21288.0001 OUTSIDE USA, COLLECT: 1-757-523-3880 SALINAS CA 93912.1622 TOD HEARING IMPAIRED: 1-800395-9020 Q Manage your account online at: com householdbank www . . HDP1 0905505 P3 0000000103 G STMT11 D 4 00017428 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On our reck Account Number ;111150 New Balance $2,272.20 IAinimum Payment w '582.00 Pavment Due Date 02/1810 Current Payment Due li If4.2o Include account number on check to HSBC CARD SERVICES. Do not send cash. S id vyment 7 to 10 days prior to Payment Dire Date to ensure timely delivery. To avoid an ov( 'im ee on your New Balance, pay the Current Payment Due. Amount Enclosed WILLIuaM L WOODSIDE 219 R PINE ST MOUNT HOLLY SPRINGS PA 17065-1123 Iiltllrll11111111111111111111111113111111lit[III rllrlhull/?l???llllrlu?lli?nlhlnlithrll??l?l'? '''??1I I II??I' HSBC CARD SERVICES PO BOX 88000 BALTIMORE MD 21288-000 BALANCE SUMMA PREVIOUS BALANCE PAYMENTSIGREDITS PURCHASES/DEBITS +`. FINANCE CHARGE + NEW BALANCE _ HOUSEHOLD BANK GOLD WILLIAM L WOODSIDE - Valued Cardmember Since 2002 1c 2 of 2 IMPORTANT INFORMATION TDD/Healing Impaired: 1-SQO-655392. _ ....---CARDMEMBER NEWS"`*""`"' Online Account Access lets you take control of your Account anytime, anywhere. Registration is easy, secure and rr itil for you at go.householdbank.com. ? MPAYMENTS TO: QUESTIONS? ' O: MAIL INQUIRIES HSBCCAR SERVICES 24-HOUR CUSTOMER SERVICE HSBC CARD SERVICES PO BOX 1-800477-6" BOX 8 BALTIMORE MD 2128&0001 OUTSIDE USA, COLLECT: 1-757-523-3880 SA LINAS CA CA 93912-1822 TDD HEARING IMPAIRED. 1-800-3953020 .L Manage your account online at: www.householdbank.com HDP1 090550 5 23 0000000103 G STMT11 D 4 00017428 PLEASE DETACH AND RETURN BOTTOM PORTION WITH YOUR PAYMENT: To Assure Proper Credit Please Write Your Account Number On ' our teck