HomeMy WebLinkAbout14-2400 Supreme Co .�" ` ennsylvania
COu)C' CO111YIO leas For Prothonotary Use Only:
Docket NO: S'
Cud �`� Y County #�
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S Complaint El Writ of Summons 13 Petition
Transfer from Another Jurisdiction [3 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
American Express Centurion Bank, an Industrial Bank Off Tina L Morelli Avara
; T
I Are money damages requested? E3 Yes No Dollar Amount Requested: Owithin arbitration limits
(check one) ®outside arbitration limits
O
N Is this a Class Action Suit? E3 Yes 0 No Is this an MDJAppeal? 0 Yes El No
�l Name of Plaintiff /Appellant's Attorney: DEMETRIOS H TSAROUHIS 140309
Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. if you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
Intentional Buyer Plaintiff Administrative Agencies
Malicious Prosecution ®X Debt Collection: Credit Card Board of Assessment
Motor Vehicle Debt Collection: Other Board of Elections
Nuisance Dept. of Transportation
Premises Liability Statutory Appeal: Other
'S 0 Product Liability (does not include
- mass tort) ®Employment Dispute:
Slander/Libel/ Defamation Discrimination
C Other: Employment Dispute: Other Zoning Board
T Other:
Other:
O MASS TORT
® Asbestos
Tobacco
Toxic Tort - DES
Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
® Toxic Waste
Other: ® Ejectment [3 Common Law /Statutory Arbitration
B Eminent Domain /Condemnation 0 Declaratory Judgment
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Landlord /Tenant Dispute Non- Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Commercial ® Quo Warranto
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Updated 1/1/2011
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION – LAW
American Express Centurion Bank, an
industrial bank organized under the laws
of the State of Utah ;
Plaintiff
U !
No.
V.
TINA L MORELLI AVARA"
Defendant �
140309.001
C
NOTICE TO DEFEND -- — `-'
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by 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.
Cumberland County Bar Association
34 S. Bedford Street
Carlisle, Pennsylvania -
telephone number 717- 249 -3166
1 do hereby certify that the within is a and correct
copy of the original filed in thi tion.
Demetrios H Tsarouhis
CD
11
�lL C7- 90
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION — LAW
American Express Centurion Bank, an
industrial bank organized under the laws
of the State of Utah,
Plaintiff
No.
V.
TINA L MORELLI AVARA,
Defendant 140309.001/
COMPLAINT
Plaintiff, American Express Centurion Bank, an industrial bank organized under the laws of
the State of Utah, by and through its counsel, Demetrios H. Tsarouhis, files this Complaint and aver
as follows:
1. Plaintiff, American Express Centurion Bank, an industrialbank organized under the
laws of the State of Utah, ( "Plaintiff') is a UT business corporation having its corporate offices at
4315 S 2700 W, SALT LAKE CITY UT 84184.
2. Defendant, TINA L MORELLI AVARA , is an adult individual resident of
Pennsylvania who maintains an address at 6316 STEPHENS XING , MECHANICSBURG PA
17050-2338.
3. At all relevant times herein, Plaintiff was engaged in the business of extending credit
to potential clients.
4. Defendant applied for and received a credit card issued by Plaintiff with the account
number ending in * * * * * * * ** *22008.
5. Use of the credit card was subject to the terms and conditions of the Cardmember
2
Agreement (hereinafter "Agreement "). Incorporated herein by reference as if set forth herein at
length and attached as Exhibit "A" is a true and correct copy of the Cardmember Agreement.
6. Defendant used the credit card with account number ending in * * * * * * * * * *22008,for
purchases, cash advances and /or balance transfers. Use of the card in this manner constituted
acceptance of the terms and conditions and subjects the Defendant to the terms and conditions
contained therein.
7. The Defendant was mailed monthly account statements relative to the Defendant's
use of the subject credit card. Incorporated herein by reference as if set forth herein at length and
attached as Exhibit `B" is a true and correct copy of the most recent statement.
8. The Defendant defaulted under the terms of the Agreement by failing and refusing to
make monthly payments on the account as they became due.
9. The account became delinquent on or about 03/11/2013 and Defendant has failed to
pay any amounts since that time.
10. The principal amount due at such time was $10,809.62.
11. Pursuant to the terms ofthe Agreement, Defendant is liable to Plaintiff for court costs.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant as follows:
a) Judgment in the amount of $10,809.62 due on the account;
b) Costs of suit;
COUNT II
Alternative to Count I - Unjust Enrichment
12. Plaintiff incorporates the allegations of every paragraph enumerated above this
Complaint as' if said paragraphs were fully set forth here at length.
3
13. At Defendant's request, Plaintiff conferred a benefit upon Defendantbyprovidingthe
credit described in the exhibits attached hereto.
14. Defendant received and accepted the benefit of said credit provided by Plaintiff.
15. At all times material hereto, Defendant was aware that Plaintiff was providing the
aforesaid credit to Defendant and that Plaintiff expected to be paid for such.
16. At all times material hereto, Defendant, with the aforesaid knowledge, permitted
Plaintiff to provide said credit and to incur damages.
17. At all times material hereto, Defendant was unjustly enriched by retaining the benefit
of receiving said credit without paying Plaintiff fair and reasonable compensation.
18. Allowing Defendant to retain the benefit of said credit without paying fair
compensation would be unjust.
19. By reason of the aforesaid unjust enrichment of Defendant at Plaintiffs expense, an
implied contract exists between Plaintiff and Defendant and Defendant is obligated to pay Plaintiff
the quantum meruit value of the credit described in the exhibits attached hereto in the amount of
$10,809.62.
4
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant as follows:
a) Judgment in the amount of $10,809.62 due on the account;
b) Costs of suit.
Respectfully Submitted,
DEMETRIOS H. TSAROUHIS
I.D. #88513
Attorney for Plaintiff
21 S. 9 th Street —Suite 200
Allentown, PA 18102
610- 439 -1500
Date: April 14, 2014
140309.001
5
nmeR
� r�wacss
Cardmember Agreement: Part 1 of 2 As of: 10/30/2010 How Rates and _Fees Work
Blue from American Express
Issuer. American Express Centurion Bank Cardmember Name: Tina L Morelli-Avara - Calculating The Annual Percentage Rate (APR) for variable rates is determined by adding an amount (margin)
Credit Limit: $10,400 (Cash Advance Limit: $200) Account Ending In: 22008 APRs and DPRs to the Prime Rate (see Determining the Prime Rate in Part 2). The Daily Periodic Rate (DPR) is
Rates and Fees Table - 1/365th of the APR, rounded to one ten - thousandth of a percentage point.
Interest Rates Rate Description Prime +Margin APR DPR
Annual Percentage Rate o -- - - - - -- - -- Purchase Prime +11.99% 15.24% 0.0417%
(APR) for Purchases 1 5.24 �0 _. - . - Balance Transfer Prime + 11.99 15.24% 0.0417%
This APR will vary with the market based on the Prime Rate. Cash Advance Prime + 21.99% 25.24% 0.0691%
APR for Balance Transfers 115.24 for any balance transfer requests we may accept. Penalty Prime +23.99% 27.24% 0.0746
This APR will vary with the market based on the Prime Rate.
APR for Cash Advances 25.24%
This APR will vary with the market based on the Prime Rate. Penalty APR for The penalty APR applies to new transactions it. If the Penalty APR applies to a balance, it will
new transactions you do not pay at least the Minimum apply to charges added to that balance 15 or
Penalty APR and When it 27.24 % Payment Due by the Closing Date of the more days after we send you notice.
Applies This APR will vary with the market based on the Prime Rate. billing period in which it is due,
• you do not pay at least the Minimum We will review your Account every 6 months after
This APR will apply to your account if you: - Payment Due by the Payment Due Date 2 the Penalty APR is applied. The Penalty APR will
1 make one or more late payments; or - times in 12 billing periods, or continue to apply until you have made timely
2; make a payment that is returned. your payment is returned by your bank. payments with no returned payments during the 6
How Long Will the Penalty APR Apply? If the Penalty APR is applied, it months being reviewed.
will apply for at least 6 months. We will review your Account every 6 months Penalty APR for If you do not pay at least the Minimum Payment Due within 60 days after its Payment Due Date, we
after the Penalty APR is applied. The Penalty APR will continue to apply until existing balances can apply the penalty APR to those balances it does not already apply to. After you pay on time for
you have made timely payments with no returned payments during the 6 6 billing periods in a row, the penalty APR will no longer apply to those balances (but it may. still
months being reviewed. apply to other balances as described above). _
Paying Interest Your due date is at least 25 days after the dose of each billing period. We will
not charge you interest on purchases if you pay your entire balance by the due We add fees to a purchase balance, unless we ten you otherwise.
date each month. We will begin charging interest on cash advances and balance
transfers on the transaction date. Annual Membership This fee is on the Rates and Fees Table on page 1 Open 1.
For Credit Card Tips from To learn more about factors to consider when applying for or using a credit card, late Payment Up to $35. If we do not receive the Minimum Payment Due by its Payment Due Date, the fee is $25.
the Federal Reserve Board visit the website of the Federal Reserve Board at If this happens again within the next 6 billing periods, the fee is $35. However, the late fee will not
exceed the Minimum Payment Due. Paying late may also result in a Penalty APR. See Penalty
APR for new transactions and Penalty APR for existing balances above.
Annual Membership Fee None _ Returned Payment Up to $35. If your payment is returned unpaid the first time we present it to your bank, the fee is
Transaction Fees - - $25. If this happens again within the next 6 billing periods, the fee is $35. However, the returned _
Balance Transfer Either $5 or 3% of the amount of each transfer, whichever is greater. payment fee will not exceed the Minimum Payment Due on the last Payment Due Date before the
• Cash Advance Either $5 or 3% of the amount of each cash advance, whichever is greater. payment is returned. A returned payment may also result in a Penalty APR. See Penalty APR for
Foreign Transaction 2.7% of each transaction after conversion to US dollars. new transactions above.
Penalty Fees Retumed Cheek $38 if you use your card to cash a check at one of our approved locations and the check is returned
• Late Payment Up to $35 - unpaid. We will also charge you the unpaid amount
• Returned Payment Up to $35 - Overlimit None. See Credit limit and cash advance limit in Part 2.
• Overiimit None - Statement Copy $5 for each statement you request except for the 3 most recent billing periods.
How we calculate Interest: We use the Average Daily Balance method (including new transactions). See the Account Reopening $25 if your Account is cancelled, you ask us to re -open it and we do so.
How we calculate interest section in Part 2.
Your Billing Rights: See Part 2 for information on how to exercise your rights to dispute transactions. Balance Transfer 3% of the transaction, with minimum of A d fee may apply l stated in a promotional
_ otter or at the time of a transaction. This fee ee f
is a finance charge. We will add it to the same balance
_ as the balance transfer.
Cash Advance 3% of the withdrawal and other services you obtain (including any fee charged by the ATM
Operator), with a minimum of $5. We will add this fee to the cash advance balance.
Foreign Transaction 2.7% of the converted U.S. dollar amount This fee is a finance charge. See Converting charges
T made in a foreign currency in Part 2.
F 11 Part 1, Part 2 and any supplements or amendments make up your Cardmember Agreement
X
Cr
CMAEUAAC0000105 Page 1 of 9 CMAEUAA00000105 Paga 2 of 9
I
AMCR
kXVRESS
Cardmember Agreement: Part 2 of 2 CD 27738 About your payments
Introduction When you must pay You must pay at least the Minimum Payment Due by at least the Minimum Payment Due In such time and
About your This document together with Part 1 make up the Any supplements or amendments are also part of - the Payment Due Date. The Minimum Payment Due manner by the Payment Due Date shown on your
Cardmember Agreement Cardmember Agreement (Agreemen) for the the Agreement. When you use the Am and Payment Due Date are shown on each billing billing statement. ount (or you statement.
Amount identified on page 1 of Part 1. sign or keep the card), you agree to the terms of the Each statement also shows a Closing Date. The
Agre ement. Each statement also states the time and manner by Closing Date is the last day of the billing period
Changing the Agreement We may change this Agreement, subject to to some tens may require 45 days advance notice, which You must make your payment for it to be covered by the statement. Each Closing Date is
credited as of the same day it is received. For your about 30 days after the previous statements Closing
busi may do this in response to the and we will tell you in the noticed you have the right
businesss, , legal law. o or r competitive environment. to reject to be considered on time, we must r eceiv e Dale. a change. We cannot change certain teens How to make payments Make
We cannot increase the interest rate on existing during the first year of your Cardmembership, p y payments to us in U.S. dollars with: your billing statement. If we receive it after that time,
balances except in limited circumstances. Changes a single check drawn on a U.S. bank, or we will credit the payment on the day after we
• a single negotiable instrument clearable through receive it.
Words we use in We, us, and our mean the issuer shown on page 1 added to your Amount, such as purchases, cash the U.S. banking system, for example a money
the Agreement of Part 1. You and your mean the person who advances, balance transfers, fees and interest order, or If your payment does not meet the above
• an electronic
applied for this Account and for whom an opened charges. A purchase is a charge charge A
goods or payment that can be cleared through requirements, there may be a delay in crediting your
Account. This may result in late fees and additional
the Amount You and your also mean anyone who services. A cash advance is a charge to gel rash the U.S. banking system.
agrees to pay for this Amount. You are the Basic or cash equivalents. balance r interest charges (see How Rates and Fees Work on
r is it charge When making a payment by mail: page 2 of Part 1).
Cardmember. You may request a card for an to pay an amount you u owe on an r credit card make a separate payment for each amount,
Additional Cardmember (see About Additional amount. mail ur If we decide to accept a payment made in a foreign
Cardmembers in Part 2). Yo payment to the address shown the
To pay by a certain date means to send your payment coupon on your billing statement, t, cuffen and c/. we will choose a rate to convert your
Card means any card or other device that we issue payment so that we receive it and credit it to your write your Account number on your check or payment into U.S. dollars, unless the law requires us .
to access your Amount. A charge is any amount Account by that date (see About yourpayments in negotiable instrument and include the payment to use a particular rate.
Part 2). coupon. If we process a late payment, a partial payment, or a
About using your card If your payment meets the above requirements, we payment marked with any restrictive language, that
will credit it to your Amount as of the day we receive will have no effect on our rights and will not change
Using the card You may use the card to make purchases. At our Amount status or changes to your card number or it, as long as we receive it by th e time di in this Agreement.
discretion, we may permit you to make cash expiration dale. You must notify the merchants How or balance Transfers. You cannot transfer directly we apply payments Your Amount may have balances with different After the Minimum ly if you want them to stop charging your Payment Due has been paid,
balances from any other account issued by us or our Amount. and credits interest rates. For example, purchases may have a we apply your payments to the balance with the
lower interest rate than cash advances. If your highest interest rate, and then to balances with
affiliates. Kee our card safe and don't let anyone else use
PY Y Amount has balances with different interest rates, lower interest tales.
You may orange for certain merchants to charge it. If your card lost or stolen or your Account is here is how we generally apply payments in a billing
your Amount regular intervals. may (but are being used without your permission, contact right period: In most cases, we apply a
not required to) ) tell these merchants is about your away. You may not use your Account for illegal al We apply your payments, up to the Minimum balance as the related charge For example, we
a Payment Due, first the balance with the lowest apply a credit for a purchase to the purchase
.
Promise to pay You promise to pay all charges, including: interest rate, and then balance We may apply payments and credits within n t.0 balances with higher if in rate in any order we choose balances, and among balances with the same
• charges you make, even if you not present your card or sign for the transaction, interest Tales.
• charges that other people make if you let them use your Amount, and '
• charges that Additional Cardmembers make or permit others to make. About your Minimum Payment Due
Credit limit We assign a Credit Limit to your Amount. We may You agree to manage your Amount so that How we calculate your To calculate the Minimum Payment Due for each
and cash advance limit make part of your Credit Limit available for cash your Amount balance (including fees and interest) Minimum Payment Due statement, we start with the highest of the following
advances (Cash Advance Limit). There may also be is not more than your Credit Limit, and �RMpL. um
three amounts:
• limit on the amount you can withdrew from ATMs in • your cash advance balance (including fees and (1) 2% of the New Balance (excluding late fees on
• given period. The Credit Limit and Cash Advance interest) is not more than your Cash Advance the statement); or fetes S2R { AeXE'' «•
Limit are shown on page 1 of Part 1 and on each Limit. (2) interest charged on the statement plus 1% of yrnhaa tR Caasar
billing statement. We the New Balance (excluding late fees and s;
may approve charges that cause your Amount o
interest on the statement) not to d 4 %
We may increase or reduce your credit Limit and balance to go over your Credit Limit. If , exceed we do this, f
,tO 8 8�1t
Cash Advance Limit. We may do so even if y ou a
y y pay we will not charge an ovedimit fee. H we ask you to the New Balance; or on time and your Amount is not in default. promptly pay the amount of your Amount balance _ (3) $15.
above your Credit Limit, you agree to do so. Then we add late fees on the statement, round to
decline to authorize a charge. Reasons we We are not responsible
the nearest dollar, and add any amount past due
Declined transactions We may rg authorize for any losses you incur if
may do m
Nis include suspected fraud and our we do not authorize a charge. And we are not However, your Minimum Payment Due will not
assessment of your creditworthiness. This may occur responsible if any merchant refuses to accept the exceed your New Balance.
even if the charge would not cause you to go over card. - Adjusting your If you regularly pay more than the Minimum Payment Due described above, we may adjust it in future
your Cr edit L imit and y A i not in de Minimum Payment Due billing periods. This may let you make a smaller minimum payment from time to time. But if you then do
not regularly pay more than the Minimum Payment Due described above, we wit stop adjusting it and
return to the formula above. If we start or stop adjusting your Minimum Payment Due, we will do so for at
least six billing periods in a row. To adjust the Minimum Payment Due, we will not exclude late fees from
(1) and not add 1% of the New Balance in (2). Then, if (2) is the highest (but less than 4% of the New
Balance), we will add $15. If we do the adjustment, we will not include any new late fees in the Minimum
Payment Due. continued on next page...
CMAEUACM0000102 Page 3 of 9 CMAEUACM0000102 Page 4 of 9
® R.,
...continued /mm previous page We will do this if over six billing periods the sum of your payments Is more than the sum of the Minimum Determining the We use the Prime Rate from the Money Rates use the Prime Rate from an other news
Pa
Payments Due not adjusted, except an amount p ast due is counted on Y y paper of
Y ( 1 Y P only the first of those six periods). Prime Rate section (or successor section) of The Wall Street general simulation in New York, New York. Or we
We u also make the adjustment if over six billing periods the sum s. the Minimum Payments Due (not Journal. The e Prima Rate for each billing period is the
adjusted) d) is net than and equals the sum of your payments. However, we will net make the may choose to use a similar published rate.
Prime Rate published in The Wall Street Journal adjustment if su the sum of Minimum um Payments Due is zero and we did not adjust the Minimum Payment Due days before the Closing Date of the billing period. If the Prime Rate increases, variable APRs (and
th l ast ti me it w n ot zem. corresponding DPRs) will increase. In that case, you
The Wall Street Journal may not publish the Prime y pay more interest and may have a higher
About interest charges Rate on that day. If it does not, we will use the Prime Minimum Payment Due. When the Prime Rate
When we charge interest We charge interest beginning on the date of each transaction. You can avoid paying interest on purchases Rate from the previous day it was published. If The changes, the resulting changes to variable APRs
as described below. However, you cannot avoid paying interest on cash advances and balance transfers. Wag Street Journal is no longer published, we may take effect as of the first day of the billing period.
If you pay the New Balance on every statement by by the Payment Due Date, we will not charge Other important information
the Payment Due Date, we will not charge interest interest on purchases from the date of your About Additional At your request, we may issue cards to Additional You authorize us to give Additional Cardmembers
on purchases. payment to the Closing Date of the billing period in Cardmembers Cardmembers. They do not have accounts with us information about your Account and to discuss it
If you pay the New Balance on a statement by the which You made that payment. But we will charge but they can use your Account subject to the terms with them.
Payment Due Date and then you pay less than the interest on purchases from the beginning of that of this Agreement. You are responsible for all use of
New Balance on the following statement by the billing period until the date of your payment. your Account by Additional Cardmembers and If you want to cancel an Additional Cardmembers
Payment Due Date, we will not charge interest on • you pay the New Balance on each of the next two anyone the allow to use right to use your Account (and cancel their card) you
statements b their Payment Due Dates, we will Y Y your Account. You must must tell us.
the portion of the purchase balance that st apply y purchases pay for all charges they make.
that payment to. But we will charge interest on not charge interest on purchases on the following
unpaid purchases. statement. Converting charges made If you make a charge in a foreign currency, we will interbank rate we identify from customary banking
In a foreign currency convert it into U.S. dollars on the date we or our sources on the conversion date or the prior business
If you do not pay the New Balance on a statement Also, we will not charge interest on purchases on a agents process it. Unless a particular rate is day. This rate may differ from rates that are in effect
by the Payment Due Date and then: statement if the Previous Balance on that statement required by law, we will choose a conversion rate on the date of your charge. We will bill charges
• you pa y th New Balan on th n ext statement is zero or a credit balance. that is acceptable to us for that date. The rate we converted by establishments (such as airlines) at the
How we calculate interest We calculate interest for a billing period by first figuring the interest on each balance. Different categories use is no more than the highest official rate rates they use.
of transactions such as published by a government agency or the highest
purchases and cash advances may have different interest rates. Balances
within each category may also have different interest rates. Changing your You must notify us immediately if you change the: If You have more than one account, you need to
We use the Average Daily Balance method Daily Balance billing address mailing address to which we send billing notify us separately for each account.
statements; or
(including new transactions) n . he to figure interest For each day a DPR is in effect, we figure the daily e-mail address to which we send notice that your We may update your billing address if we receive
charges for each balance. The total interest charged balance by:
for a billing period is the sum of the interest charged •taking the beginning balance for the day, billing statement is available online. information that it has changed or is incorrect.
on each balance. adding any new charges, Closing your Account You may dose your Account by calling us or writing to us.
Interest subtracting any payments or credits; and Cancelling or suspending We may: We ma these things at our discretion,
do any of
The interest charged for a balance in a billing period, • making any appropriate adjustments. your Account •cancel your Account. even if you you pay o f time and your Account is not in
except for variations roused by rounding, equals: We add a new charge to a daily balance as of its suspend the ability to make charges, default.
• Average Dail Balance (ADB) x transaction date. cancel or suspend any feature on your Account,
Daily Periodic Rate (DPR) x If your Account is cancelled, you must destroy your
Beginning balance • e
• number of days the DPR was in effect. of billing beginning anti merchants that cards. We may agree to reinstate your Account after
For the first day g period, the b innin notify your Account has been a cancellation. If we do this, we ma
ADB balance is the ending balance for the prior billing cancelled or suspended. Y:
• reinstate any additional cards issued on your
To get the ADB fora balance, es add up its dairy period, including unpaid interest. For the rest of the If we do any of these, yon must sfill pay us for all Account,
balances. Then we divide the result by the number billing period, the beginning balance is the previous charges under the terms of this Agreement. charge you any applicable annual fees, and
of days the DPR for that balance was in effect. If the days daily balance plus an amount of interest equal charge you a fee for reinstating the Account.
daily balance is negative, we treat it as zero. to Me previous day s daily balance multiplied by the About default We may consider your Account to be in default if:
DPR DPR for that balance. This method of figuring the If we consider our Account in default, we may:
Y
A DPR is 1/365th of an APR, rounded to one ten- beginning balance results in daily compounding of you violate a provision of this Agreement, suspend your ability to make charges,
thousandth
interest Y Y • you give us false information, • cancel or suspend an feature on our Account,
of a percentage point. Your DPRs are •you file for bankruptcy, •require you to pay more than your Minimum '
shown in How Rates and Fees Work on page 2 of When an interest rate changes, the new DPR may • you default under another agreement you have Payment Due immediately, and
Part 1 come into effect during not just at the beginning with us or an affiliate, require you to pay your Account balance
,. of the billing period. When this happens, we will you become incapacitated or die, or immediately.
., I create a new balance and apply the new DPR to it. we believe you are unable or unwilling to pay your
&4ilfp R ,. - mgt f`" cif,' To get the beginning balance on the first day for this debts when due.
a new balance, we multiply the previous days daily Collection
E balance by the old DPR and add the result to Collection costs You agree to pay all reasonable costs, inducting attorneys' fees, that we incur to collect amounts you owe. that
days dairy balance. Credit reports You agree that we may obtain credit reports about term of this Agreement. This may have a negative
Other methods you, investigate your ability to pay, and obtain impact on your credit record.
To figure the ADB and interest charges, we may use information about you from other sources. And you If you believe information we have given to a credit
other formulas or methods that produce equivalent agree that we may use such information for any agency 9
results. Also, we may choose not to charge interest purposes, subject to applicable law. reporting 9 cy is incorrect, write to us at:
American Express Credit Bureau Unit, P.O. Box
on certain types of charges You agree that we may give information about your 981537, El Paso, TX 79998 -1537. When you write
Account to credit reporting agencies. We may tell a to us, tell us your Account number and the specific
credit reporting agency if you fai to c omp ly with any information you believe is incorrect
CMAEUACMODD0102 Page 5 of 9 CMAEUACM0000102 Page 6 of 9
Nv3Gft! 1 �
.. EJ6•REaS '.
Sending you notices We mail you notices through the U.S. mail, postage prepaid, and address them to you at the latest billing We do not waive our rights We may choose to delay enforcing or to not exercise rights under this Agreement. If we do this, we do not
address on our records. Any notice that we send you this way is deemed to be given when deposited in waive our rights to exercise or enforce them on any other occasion.
the U.S. m Governing law Utah law and federal law govern this Agreement and your Account. They govern without regard to internal
We may contact you From time to time, we may contact you about topics to ensure the quality of customer service or when it principles of conflicts of law. We are located in Utah. We hold your Account in Utah. We entered into this
ranging from servicing to marketing offers to is required by law. Agreement with you in Utah.
collecfing amounts you owe. We may monitor and You can choose to not receive marketing offers from Arbitration
record phone calls between you (or any Additional us. To do this, call us at 1-800- 297 -8378 or log on to
Cardmembers on your Account) and us. We do this �y,,�. americenexpress.mrrdmmmunicebons This Arbitration provision sets forth the any claim that you property file and pursue in RIGHT OR AUTHORITY FOR ANY CLAIMS
circumstances and procedures under which a small claims court of your state or TO BE ARBITRATED ON A CLASS ACTION
About insurance products We or our affiliates may tell you about insurance and or another affiliate is the insurer or coinsurer, claims may be arbitrated instead of litigated in municipality so long as the claim is individual BASIS OR ON BASES INVOLVING CLAIMS
non - insurance products, services or features that Compensation may influence what products and court. and pending only in that court. BROUGHT IN A PURPORTED
may have a fee. One of our affiliates may act on providers we or our affiliates tell you about. Definitions Initiation of Arbitration REPRESENTATIVE CAPACITY ON BEHALF
behalf of a provider of these products. The affiliate We may share information about you with our As used in this Arbitration provision, the term Any claim shall be resolved, upon the election OF THE GENERAL PUBLIC, OTHER
may be compensated for this. The insurance affiliates so they can identify products that may claim means any claim, dispute or by you w us, by arbitration pursuant to this CARDMEMBERS OR OTHER PERSONS
products are not offered or said by us or on our interest you. We may be compensated for this controversy between you and us arising from Arbitration provision and the code of SIMILARLY SITUATED. The arbitrators
behalf. Our affiliates may gel additional information. or relating to your Account, this Agreement, procedures of the arbitration organization to authority to resolve claims is limited to claims
c ompensation when Amex Assurance Company the Electronic Funds Transfer Services which the claim is referred in effect at the time between you and us alone, and the
Now we handle electronic When you pay us by check, you authorize us to If we do this, your payment may be deducted from Agreement, and any other related or prior the claim is filed (code), except to the extent arbitrators authority to make awards t. limited
agreement that you may have had with us, or the code conflicts with this Agreement.
to awards to you and us alone. Furthermore,
debits from your checking electronically a deduct the amount from your bank or your bank or other asset account on the same day g y Y claims brought by you against us, or by us
account other asset account. we receive your check. Also, you will not receive the relationships resulting from any of the Claims shall be referred to either JAMS or the against you, may not be joined or
above agreements, except for the validity, American Arbitration Association (AAA), as
We may process the check electronically by that cancelled check with your bank or asset enforceability or scope of this Arbitration selected by the party electing to use consolidated in arbitration with claims brought
transmitting to your financial institution: account billing statement- provision. For purposes of this Arbitration arbitration. If our selection of either of these by or against someone other than you, unless
• the amount, If we cannot collect the funds electronically, we may provision, you and us also includes any organizations is unacceptable to you, you agreed to in writing by all parties. No
• the routing number, issue a draft against your bank or other asset corporate parent, or wholly or majority owned may select the other organization within 30 arbitration award or decision will have any
• the account number, and account for the amount of the check. subsidiaries, affiliates, any licensees, days after you receive notice of our selection. preclusive hand as to issues or claims in any
• the check serial number. predecessors, successors, assigns, any For a copy of the code, to file a claim or for dispute with anyone who is not a named parry
purchaser of any accounts, all agents, other information, contact either: JAMS (1920 to the arbitration. Notwithstanding any other
ExpressPay Cards issued on your Account may be equipped with ExpressPay. ExpressPay enables you to make employees, directors and representatives of Main St #300, Irvine, CA 92614 or provision of this Agreement (including but not
charges without having the card swiped or imprinted. You can call us to deactivate ExpressPay at any limited to the Continuafion subsection below)
any of the foregoing, and other persons N or AAA (335 Madison Ave,
ti me. Also, w may de a ct ivat e ExpressPay at any tim referred to below in the definition of claims. New
e. New Y ork, and without waiving either party's right to
York, N NY 10017 or adr.org).
Act of 1974 notice Some federal agencies may accept the card under authority of statute. When you make charges at these Claim includes claims of every kind and appeal such decision, should any portion of
Privacy addition to the organizations a ov
listed abe, this Restrictions on fe subsection be
d information agencies, we collect certain charge infoation. That information to t'
n may be put to routine uses such as nature, including but not limited [o, initial claims may be referred to any other deemed invalid or unennenforcorcea able, then the �
rocessin billing and collections. It may also be aggregated for reporting, analys and marketing use. claims, munterdsims, cross-daims and third -
processing. 9 Y Ys 9 arbitration organization that is mutually entire Arbitration provision (other than this
Other routine uses by agencies may be published in the Federal Register. party claims and claims based upon contract' agreed upon in writing by you and us, or to an sentence) shall not apply.
(including balance transfer add the fee to the same balance that we add the tort, fraud and other intentional torts, statutes, arbitration organization or arbitrator(s)
Convenience Cheeks Convenience checks
( 9 regulations, common law and equity. Claim Arbitration Procedures
re
checks) a checks that we may send to access convenience check transaction to. appointed pursuant . C. . 5 of the Federal
Y you also includes claims by or against any third Arbitration Ad, 9 U.S. This Arbitration provision is made pursuant to
your Amount The fallowing terms will apply to use W will charge $29 each time cha a party using or providing anroduct, service as it may be transactions involving interstate commerce
d t hat those checks unless otherwise disclosed on a convenience check. amended (FAA ask us to stop or benefit in connection with any account p organization and d arbitrator(s) will y enfo the A sed with the it provided d t hat an ch and shall be governed by the FA The �
rce
check. (including, but not limited to, credit bureaus, arbitration shall be governed by the applicable
If you use convenience check, i,
i
A convenience check is not a card. You not use terms subse tction sal forth below. the Restrictions on Arbitration
code, except that this Agreement shall apply if
third parties who accept the card, third parties j
we decline t, you may have to pay y may decline it. If my returned check convenience checks to pay this any other account who use, provide or participate in services there are any conflicts. The arbitrator shall
with us or our affiliates. If you use a ro
a convenience s
arfree benefit program, enrollment nt services Significance of Arbitration apply applicable substantive law consistent
fees or other penalties to whomever you wrote the check, we will apply the: and rewards programs, credit insurance IF ARBITRATION IS CHOSEN BY ANY with the FAA and applicable statutes of
check. • cash advance APR it you make it payable to cash, companies, debt collectors and all of their PARTY WITH RESPECT TO A CLAIM, limitations, shall honor claims of privilege
If you use a convenience check and we honor it, we to you, or to a bank, brokerage or similar asset agents, employees, directors and NEITHER YOU NOR WE WILL HAVE THE recognized at law, and, at the timely request
will charge interest beginning as of the date we account, or to a mortgage or insurance provider. representatives) if and only if, such third party RIGHT TO LITIGATE THAT CLAIM IN of either party, shall provide a bdef written
receive the check. You cannot avoid paying interest purchase APR if you make it payable to a is a party in connection with the claim. The COURT OR HAVE A JURY TRIAL ON THAT explanation of the basis for the decision. The
on convenience check transactions. merchant. term claim is to be given the broadest CLAIM. FURTHER, YOU AND WE WILL arbitration proceeding shall not be governed l
We will charge a fee for each convenience check balance transfer APR if you use it to transfer a possible meaning that will be enforced and NOT HAVE THE RIGHT TO PARTICIPATE by any federal or state rules of civil procedure
transaction. This fee is 3% of the transaction, with a balance from another creditor. includes, by way of example and without IN A REPRESENTATIVE CAPACITY OR AS or rules of evidence. Any party may request
minimum o f $5. This fee is a finance cha e. We w penalty APR if it applies to your Account. limitation, any claim, dispute or controversy A MEMBER OF ANY CLASS OF that the arbitrator expand the scope of
n7 that arises from or relates to (a) any of the CLAIMANTS PERTAINING TO ANY CLAIM discovery by doing so in writing and copying
Changing benefits We have the right to add, modify or delete any benefit, service, or feature of your Amount at our accounts created under any of the SUBJECT TO ARBITRATION. EXCEPT AS any other parties, who shall have 15 days to
discretion. agreements, or any balances on any such SET FORTH BELOW, THE ARBITRATOR'S make objections. The arbitrator will notify the
Assigning the Agreement We may sell, transferor assign this Agreement and your Amount. We may do so at any time without accounts, (b) advertisements, promotions or DECISION WILL BE FINAL AND BINDING. parties of his/her decision within 20 days of
oral or written statements related to any such NOTE THAT OTHER RIGHTS THAT YOU any objecting party's submission. The
notifying you. You may not sell, assign or transfer your Amount or any of your obligations under this accounts, goods or services financed under OR WE WOULD HAVE IF YOU WENT TO arbitrator shall take reasonable steps to
Agreement - any of the accounts or the terms of financing, COURT ALSO MAY NOT BE AVAILABLE IN preserve privacy. The arbitrators award shall
c the benefits and services related to ARBITRATION. be final and binding, Assigning claims If you dispute a charge with a merchant we may credit the Amount for all or pan of the disputed charge. a g, except for any right of
we do so, you assign and transfer to us all rights and claims (excluding tort claims) against the merchant. Cardmembership (including fee -based or free Restrictions on Arbitration appeal provided by the FAA: however, either
You agree that you will not pursue any claim against the merchant for the credited amount. And you must benefit programs, enrollment services and IF EITHER PARTY ELECTS TO RESOLVE A party shall have 30 days to appeal that
cooperate with us if we decide to do so. rewards programs), and (d) your application CLAIM BY ARBITRATION, THAT CLAIM decision by notifying the arbitration
for any account. We shall not elect to use SHALL BE ARBITRATED ON AN organization and any other parties in writing.
arbitration under this Arbitration provision for INDIVIDUAL BASIS. THERE SHALL BE NO
continued on next page...
CMAEUACM0000102 Page 7 of 9 CMAEUACM0000102 Page 8 of 9
l
nest
s�mr. Ss
...continued from previous page Payment of Fees arbitration with us.
The organization will then appoint a three- You will be responsible for paying your share, Continuation
arbitrator panel which shall consider anew if any, 01 the arbitration fees (including filing, This Arbitration provision shall survive
any aspect of the decision objected to by the administrative, hearing and/or other fees), but termination of your Account; voluntary
appealing party. The panel shall issue its only up to the amount of the filing fees you payment of the Account balance in full by you;
decision, by majority vote, within 120 days of would have incurred if you had brought a any legal proceeding by you or us to collect a
the appealing party's written notice. Judgment claim in the stale or federal court closest to debt owed by the other; any bankruptcy by
upon any award rendered by the arbitrator or your billing address that would have had you or us; and any sale by us of your Account
panel may be entered in any court having jurisdiction. We will be responsible for any (in the case of a sale, its terms shall apply to
junsdictio n. additional arbitration fees. At your written the buyer of your AocounQ. H any portion of
a t
Location of Arbitration request, we will consider in good faith making this Arbitration provision, except as otherwise
emporary advance of all . part of your provided in the Restrictions on Arbitration
Arbitration hearings you attend shall take share of any arbitration fees. You wip not be p
place in the federal judicial district of your assessed any arbitration fees in excess of subsection, is deemed invalid or
residence. your share if you do not prevail in any unenforceable, it shall not invalidate the
remaining portions of this provision.
Your Billing Rights: Keep this Document for Future Use
This notice tells you about your rights and our While we investigate whether or not there Your Rights HYou Are Dissatisfied With
responsibilities under the Fair Credit Billing has been an error. Your Credit Card Purchases
Act. We cannot try to collect the amount in If you are dissatisfied with the goods or
What To Do H You Find a Mistake on Your question, or report you as delinquent on services that you have purchased with your
Statement that amount. credit card, and you have tried in good faith to
H you think there is an error on your • The charge in question may remain on your correct the problem with the merchant, you
statement, write to us at: statement, and we may continue to charge may have the right not to pay the remaining
American Express you interest on that amount. amount due on the purchase.
PO Box 981535 While you do not have to pay the amount in To use this right, all of the following must be
El Paso TX 79998 -1535 question, you are responsible for the We:
In your letter, give us the following remainder of your balance. 1. The purchase must have been made in
• We can apply any unpaid amount against your home state of within 100 miles of your
information: your credit limit. current mailing address, and the purchase -
• Account information: Your name and
account number. After we finish our investigation, one of two price must have been more than $50.
• Dollaramount The dollar amount of the things will happen: (Note: Neither of these are necessary if
suspected error. • ff we made a mistake: You will not have to your purchase was based on an
• Description ofpmbtem: H you think them is pay the amount in question or any interest advertisement we mailed to you, or if we
an error on your bill, describe what you or other fees related to that amount. own the company that sold you the goods
believe is wrong and why you believe it is a /f —, do not believe there was a mistake: or services.)
mistake. You will have to pay the amount in 2. You must have used your credit card for
question, along with applicable interest and the purchase. Purchases made with cash
You must contact us: fees. We will send you a statement of the advances from an ATM or with a check that
• Within 60 days after the error appeared on amount you owe and the date payment is accesses your credit card account do not
your statement. due. We may then report you as delinquent qualify.
• Al least 3 business days before an if you do not pay the amount we think you 3. You must not yet have fully paid for the _
automated payment is scheduled, if you owe. purchase.
want to stop payment on the amount you
think is wrong. If you receive our explanation but still believe If all of the criteria above are met and you are -
your bill is wrong, you must write to us within still dissatisfied with the purchase, contact us
You must notify us of any potential erors in 10 days telling us that you still refuse to pay. in writing at:
writing. You may call us, but H you do we are H you do so, we cannot report you as American Express
not required to investigate any potential delinquent without also reporting that you are PO Box 981535
errors and you may have to pay the amount questioning your bill. We must tell you the El Paso TX 79998 -1535
in question. name of anyone to whom we reported you as
and we must let those delinquent, While investigate, the same rules to
What Will Happen After We Receive Your Jelin q the disputed amount as discussed above.
I
Letter organizations know when the matter has After we finish our investigation, we will tell
When we receive your letter, we must do two been settled between us. you our decision. At that point, H we think you
things: H we do not follow all of the rules above, you owe an amount and you do not pay, we may
1. Within 30 days of receiving your letter, we do not have to pay the first $50 of the amount report you as delinquent.
must tell you that we received your letter. you question even H your bill is correct. We will also tell you if we have already
cerected the error.
2. Within 90 days of receiving your letter, we
must either correct the error or explain to
you why we believe the bill is correct.
CMAEUACM0000102 Page 9 of 9
• II I
Ann aR Blue from American Express p. 113 TINA L MORELLI AVARA Account Ending 6 -22008 p. 21
TI NA L MORELLI AVARA Payments:Your payment must be sent to the paymentaddress shown on your statement and must be received by 5 p.m. local timeat that address to
Closing Date 07/09/13 Account Ending 6 -22008 be credited as of the day it is received. Paymentswe receive after 5 pm. will not be credited to your Account until the next day. Payments must also: (1)
include the remittancecoupon from your statement (2) be made with a single check drawn on a US bankand payable in US dollars, orwith a
negotiable instrument payable in US dollars and clearablethrough the US banking system; and (3) include your Account number. If your payment does
Earn points on all of your not meet all of the above requirements,crediting may be delayed and you may incur late paymamfeesand additional interestcharges. Electronic
New Balance $10,809.62 payments must be made through an electronic payment method payable in US dollars and clearablethrough the US banking system. If we accept
purchases, everywhere you use payment in a foreign currency,we will convert h into US dollars ata conversion rate that is acceptable to us, unlessa particular rate is required bylaw.
Minimum Payment Due $1,279.00 the Card. Pleasedo not send post-dated checks as they will be deposited upon receipt Any restrictive language on a paymentwe accept will have no effect on us
Visit www.americanexpress.com /rewards without our express prior written approval. We will re- presentto yourfinancial institution any payment that is returned unpaid. Youmaypaymorethan
Includes the past due amount of $1,146.00 the Minimum Payment Due, up to your New Balance, at any time.
Payment Due Date 08/03/13 Account Summary Per Ission for Electronic Withdrawal:( 1) When you send a check for payment, you give us permission to electronically withdraw your payment from
yo posit or other asset account. We will process checks electronically by transmitting the amount ofthe check, routing number,account number
and check serial number to your financial institution, unless the check is not processableelectronically or a less costly process is available. W hen we
Late Payment Washing: If we do not receive your Minimum Payment Due by Previous Balance $10,784.62 process your check electronically, your payment may be withdrawn from your deposit or other asset account as soon as the same day we receive your
the Payment Due Date listed above, you may have to pay a late fee of up to
Payments/Credits -$0.00 check, and you will not receivethat cancelled check with your deposit or other assetaccount statement ffwe cannot collect the funds electronically
$35.00 and your Purchase APR may be increased to the Penalty APR of 27.2496. New Charges +$0.00 we may issuea draft againstyour deposit or other asset account for the amount ofthecheck.(2) By using Pay By Computer, Pay By Phone or any other
Fees +$25.00 electronic payment service of ours, you give us permission to electronically withdraw fundsfrom the deposit or other assetaccount you specify in the
Interest Charged +$0.00 amount you request. Payments using such services of ours received after B.Wp.m. MST may not be credited until the next day.
Now We Calculate Your Balance: We use the Average Daily Balance (ADB) method (including new transactions) to calculate the balance on which we
charge interest on your Account. Call the Customer Service number listed below for more information about this balance computation method and
how resulting interestcharges are determined. Themethod m use to figuetheADB mdinterest ewits in dailywmpoundingofinterest
Minimum Payment Warning: Ifyou make only the minimum payment each period, New Balance $10,809.62 Paying Interest: Your due date is at feast 25 daysafter the close ofeach billing period. We will notcharge you interest on your purchases if you pay the
you will pay more in interest and it will take you longer to pay offyour balance. For Minimum Payment Due $1,279.00 New Balance by the due date each month. We will chargeyou interest on cash advances and (unless otherwise dixlosed) balance transfers beginnin g
example: on the transaction date.
Credi[Limit $10,400.00 Foreign CumencyCharges: Ifyou makea Charge in a foreign currency, we will convert it into US dollars on the date we or ouragents process it
Ifyou make no additional You willpay off the balance i Andyouwiilpayan AvailableCredit $0.00 We will charge a fee of 2.7% of the converted USdollaramount. We will choosea conversion rate that is acceptable to us for that date, unlessa
charges and each month you shown on this statement in estimated total of -. Cash Advance Limit $0,00 particular rate is required by law. Theconversion ratewe use is no more than the highest official rate published by a government agency or the highest
pay... about._ ! AvailableCash interbankratewe identify from customary banking sourceson theconversion date or the prior businessday. This fate may differfrom ratesin effecton
-- " " "--- "' - - - - "— -- ------ - - -- - j --- - - - - - -- $0.00 the date of your charge. Charges converted by establishments (such as airlines)wilI be billed at the rates such establishments use.
Only y t he Da Billing P Credit Balance: A credit balance(desi nated CR) shown on this statements resenrsmone owed to
Minimum Payment Due 21 Years 21,534 ysin g eriod: 32 g ep y you. Owithin the six-month period following the
date of the first statement indicating the credit balanceyou do not request a refund orcharge enough to use up thecredit balance, we will send you a
Ifyou would like information about credit counseling services, call 1- 888 - 733 -4139. Customer Care checkfor thecredit balancewithin 30 daysiftheamountis f1.00ormore.
Credit Reporting: We may report information about your Account to credit bureaus. Late payments,missed payments, or otherdefaultson your
See page 2 for important information about your account. Pay by Computer Account may be reflected in your credit report.
amerx:anexpress.com /pbc
Q Your account is past due and overlimit. Ifyou would like to CustomerCare Payby Phone
receive e-mail alerts about payments, spending or fraud protection, I -W8- 25&-3741 1-800 -472 -9297
you can sign up at americanexpress.com /alerts. OSee Page 2foradditionafinformation CustomerCare& Billing Inquiries 1- 888- BLUE-741 Hearingimbaired IM Website:americanexpress.com
1- 888 - 258.3741 TTY:1- 800.221 -9950 Mobile Site: amexmobile.com
Q This statement is for information purposes only. This is not a bill. Please InternationalCollect 1- 336-393 -1111 FAX: 1-800-695-9090
contact your collections agency for account information. Disregard the Large Print Braille Statements i -SM- BLUE -741 In NY: 1-800-522-1897 CustomerCare I I,
Minimum Payment Due, our account is in default and the balance is due 1 - 888 -258 -3741 & Billing Inquiries Payments
Y Y Express Cash 1.800-CASH -NOW P.O. BOX 981535 P.O. BOX 1270
in full. EL PASO, TX NEWARKNJ
79998 -1535 07101 -1270
+ Pleasefold on the perforation below, detach and return with your payment
M PaymentCOUpon OPaybyCOmputer Payby Phone Account Ending6 -22008 C f umg* nhoado i use.
Do not staple or use paperclips amencanexpress.com /pbc 1- 800.472 -9297 Enteraccount numberon all documents. Pay Your Bill with AUtOPa Tcmnge • F your address online, visa wwwameri ooh se char updatecontactinfo
Make<heckpayable to American j
Express. •Por Name, Company name, and Forego Address or Phone charges. please call Customcv care. Avoid late fees
Ilrlrllrlllrll rll l' "1111IIIII "II I'I II I' 'I'l1'111llha ' llll'I'I Please print clearly in blue m buck ink only to the bo .es provided. Save time
TINALMORELLIAVARA Payment Due Date Deduct yourpaymentfrom Your bank
6316 STEPHENS XING 08/03/13 street Address - accountautomadcally each month
MECHANICSBURG PA 17050 -2338 - ....... " - --- -
New Balance
$10,809.62 - - - --- -- Visitamari<anaxpress.com /autopsy
rn Minimum PaymentDue City, Stare today to enroll.
X $1,279.00
Zip Code i
........ ............ .... -.
Area Code and
9111' ll' I' llllllllydllllilll9l 'l11 lllll'PI' Jill. IIlI1I1111,11 H— Ph.- -
-:
tT AMERICAN EXPRESS $ •— workPh.ne wrnfom,atbnonrowwePret «[sour
Check here'rfyouraddressor Amount Enclosed
�.} phone number has changed. P.O. BOX 1270 mae ' - " -- _ -" "' - - " "" p act' ands , rcommunxation
Note changes on reverseside. NEWARK NJ 07101 -1270 E -, _ prrracyc leasevsit
w ,n erioanexpress.com /Privacy.
0000349991015839467 001080962000127900 05 H
Arremuuu Blue from American Express- P . 313
sw*arss
TINA L MORELLI AVARA
Closing Date 07/09113 Account Ending 6.22008
Payments and Credits
Summary
Total
Payments
$000
Credits
$000
Total Paymentsand Credits $000
Detail - Indicate: Ping date
Payments Amount
06/20/13 AGENCY REMITTA 41,146.00
07/03/13' A $ 1,146,00
Fees •Ied�le POnmgdate
Amount
07/03/13" Returned Payment Fee $ 25.00
Total Fees for t his Pe riod $25.00
Interest Charged
Amount
Total Interest Charged for this P $0.00
2013 Fees and Interest Totals Year -to -Date
_ Amount
Total Fees in2013 $165.00
Total Interest in 2013 $536.12
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interestrate on youraccount.
Transactions Dated Annual Balance Interest
From To Percentage Subject to Charge
Rate Interest Rate
Purchases 05/202005 1.00%(v) $000 $000
Cash Advances 05/202005 1.00%(v) $0.00 $000
Total
$0.00
(v) Variable Race
VERIFICATION
I, Demetrios H. Tsarouhis, Esquire, verify that the statements contained in the
aforementioned Complaint are true and correct based on my communications with my client. I make
this verification because my client is unavailable to sign this document at this time. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S.A. Sec. 4904 relating to
unsworn falsification to authorities.
By:
Demetrios H. Tsarouhis, Esquire
Date: April 14, 2014
140309.001
6
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY-
nLED-or
PROIHOSO
APR 28-
CUMBERLAND COUNTY
PENNSYLVANIA
o
t Ciimbett
OFML- OF THE SltERIFP
American Express Centurion Bank
vs.
Tina L. Morelli Avara
Case Number
2014-2400
SHERIFF'S RETURN OF SERVICE
04/22/2014 05:43 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint &
Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Tina L. Morelli Avara at 6316 Stephens Crossing, Hamden Township, Mechanicsburg, PA 17050.
DAWN KELL, DEPUTY
SHERIFF COST: $39.30 SO ANSWERS,
April 23, 2014
(444 CountySuite Sheriff, Teleosoft,
RON R ANDERSON, SHERIFF
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION—LAW
American Express Centurion Bank, an
industrialbank organized under the laws :
of the State of Utah, •
Plaintiff •
•
No. 14-2400 Civil
v. : •'
•
,
TINA L MORELLI AVARA, •
mac; -
Defendant •
140309.001
PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR
TERMINATION
TO THE PROTHONOTARY/CLERK OF SAID COURT:
You are hereby authorized, empowered, and directed to enter, as indicated, the following on the
records thereof:
A. 1. nThe within suit is Settled, Discontinued, Ended and costs paid.
2. n The within suit is Settled, Discontinued, Ended WITH Prejudice and costs paid.
3. ® The within suit is Settled, Discontinued, Ended WITHOUT Prejudice and costs
paid.
* * * * *
B. 1. n Satisfaction of the Award in the within suit is acknowledged.
2. ❑ Satisfaction of Judgment, with interest and costs, in the within matter is
acknowledged.
* * * * *
C. n Other:
By:
Demetrios H. Tsarouhis
21 S. 9th St.
Allentown, PA 18102
Phone: (610) 628-2440
Fax: (610) 465-8844
Date: June 5, 2014
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
American Express Centurion Bank, an
industrialbank organized under the laws of
the State of Utah,
Plaintiff
No. 14-2400 Civil
v.
TINA L MORELLI AVARA,
Defendant • 140309 001
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the Praecipe
has been served by United States first-class mail, postage prepaid, upon the individual(s) at the
address indicated below:
TINA L MORELLI AVARA
6316 STEPHENS XING
MECHANICSBURG PA 17050-2338
By:
Demetrios H. Tsarouhis
21 S. 9th St.
Allentown, PA 18102
Phone: (610) 628-2440
Fax: (610) 465-8844
Date: June 5, 2014