HomeMy WebLinkAbout07-0049Helene B. Raush, Esq.
Bar No: 60140
Stewart & Associates, P.C.
P.O. Box 2629
Suwanee, GA 30024
(866) 990-9968 phone
(678) 684-4975 fax
CREDIGY RECEIVABLES INC.,
Plaintiff,
VS.
REBECCA P ASH,
Defendant.
To: REBECCA P ASH
746 ERFORD RD
CAMP HILL, PA 17011-1125
CUMBERLAND COUNTY
COURT OF COMMONS PLEAS
TRIAL DIVISION
Civil Action No.: 0 7 - /?[
l2
Arbitration Matter
Assessment of Damages Hearing
Not Required
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served by
entering a written appearance personally or by attorney and filing in writing with the Court your defenses
or objections to the claims set forth against you. You are warned that if you fail to do so, the case may
proceed without you and a judgment may be entered against you by the Court without further notice for
any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
This communication is from a debt collector. This is an attempt to collect a debt and any
information obtained will be used for that purpose
Helene B. Raush, Esq.
Bar No: 60140
Stewart & Associates, P.C.
P.O. Box 2629
Suwanee, GA 30024
(866) 990-9968 phone
(678) 684-4975 fax
CREDIGY RECEIVABLES INC.,
Plaintiff,
VS.
REBECCA P ASH,
Defendant.
To: REBECCA P ASH
746 ERFORD RD
CAMP HILL, PA 17011-1125
CUMBERLAND COUNTY
COURT OF COMMONS PLEAS
TRIAL DIVISION
Civil Action No.:
Arbitration Matter
Assessment of Damages Hearing
Not Required
AVISO
Usted ha sido demandado en el Tribunal. Si usted desea defender contra los reclamos
expuso en las paginas siguientes, usted debe tomar medidas dentro de veinte (20) dias despues
que esta Quej a y la nota son servidas entrando una apariencia escrita personalmente o por
abogado y clasificacion a escribir con el tribunal sus defnsas o las objecciones a los reclamos
exponen contra usted. Usted es advertido que si usted falla de hacer asi, el caso puede avanzar
sin usted y un juicio puede ser entrado contra usted por el tribual sin sota adicional para
cualquier dinero reclamado en la queja o para cualquier otro reclamo o el alivio solicitados por el
Demandante. Usted puede perder dinero o propiedad u otros derechos importantes a usted.
USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE A UN ABOGADO NI NO PUEDE PROPORCIONAR UNO, IR A NI
TELEFONEAR LA OFICINA EXPUSO DEBAJO DE AVERIGUAR DONDE USTED PUEDE
OBTENER AYUDA LEGAL.
Lawyer Referral Service
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
Helene B. Raush
Bar No: 60140
Stewart & Associates, P.C.
P.O. Box 2629
Suwanee, GA 30024
(866) 990-9968 phone
(678) 684-4975 fax
CREDIGY RECEIVABLES INC.,
Plaintiff,
vs.
REBECCA P ASH,
Defendant.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
TRIAL DIVISION
Civil Action No.: D -7 - '/?
Arbitration Matter
Assessment of Damages Hearing
Not Required
COMPLAINT
Plaintiff asserts the following cause of action against Defendant:
COUNTI
(BREACH OF CONTRACT)
1. CREDIGY RECEIVABLES INC. ("Plaintiff'), is a corporation organized and existing
under and by virtue of the laws of the State of Nevada, having its principal place of
business located at 2877 Paradise Road, Suite 303, Las Vegas, Nevada 89109. Plaintiff
is the owner of the account that is the subject matter of this action.
2. REBECCA P ASH ("Defendant") resides at 746 ERFORD RD, CAMP HILL, PA
17011-1125, located in Cumberland County.
3. Defendant requested an extension of credit from Discover Card ("Original Creditor") on
a credit card account ("Account"), specifically account number 6011-0025-3011-7282,
and by use of the account Defendant became bound by the terms in the account
agreement, an exemplary copy of which is attached hereto as Exhibit "A."
4. Original Creditor assigned all right, title and interest in and to the Account to FIRST
SELECT ("Prior Creditor"), which Account was thereafter designated by Prior Creditor
as account number 4168-1000-1943-7134. Prior Creditor sent an account agreement to
Defendant referencing and incorporating the terms and conditions of the account
agreement issued by Original Creditor. An exemplary copy of the account agreement
sent by Prior Creditor is attached hereto as Exhibit "B."
5. Prior Creditor duly assigned and transferred to Plaintiff all of its right, title and interest
in and to account number 4168-1000-1943-7134. Plaintiff remains the holder and
owner of the Account now referenced as account number 10206212 and is the successor
in interest to the terms and conditions relating thereto.
6. Plaintiff has exercised its right pursuant to the terms of said account agreement to
accelerate the time for payment of the entire balance due and owing by Defendant to
Plaintiff.
7. The amount now due and owing is the sum of $8,157.79 together with accrued pre-
judgment interest of $11,210.27 calculated at the rate of 18.00% per annum calculated
using the average daily balance method, compounded monthly from August 31, 2001 as
evidenced by the Statement of Account attached hereto as Exhibit "C."
8. Plaintiff presented the Account in writing to Defendant demanding payment, but
payment for the just amount owing has not been tendered. By reason of Defendant's
failure and refusal to pay the balance in accordance with the terms of the account
agreement(s), Plaintiff has suffered damages in the sum of $8,157.79 together with
accrued pre judgment interest of $11,210.27 calculated at the rate of 18.00% per annum
calculated using the average daily balance method, compounded monthly from August
31, 2001, plus attorney fees of $1,631.56 which may be permitted by contract or which
are otherwise permitted by applicable law.
WHEREFORE, Plaintiff demands judgment against Defendant in the sum of $8,157.79
together with accruing pre judgment interest of $11,210.27 calculated at the rate of 18.00%
per annum calculated using the average daily balance method, compounded monthly from
August 31, 2001, plus reasonable attorney fees of $1,631.56 which may be permitted by
contract or which are otherwise permitted by applicable law, and all collection and court
costs.
COUNT II - ALTERNATIVE
(UNJUST ENRICHMENT/QUANTUM MERUIT)
9. Plaintiff hereby incorporates paragraphs 1 through 8 above as though set forth in full.
10. Defendant received a monetary benefit of $8,157.79, which was in fact appreciated by
Defendant.
11. Defendant accepted the benefits of a credit account issued.
12. By virtue of the circumstances surrounding the request for funds made, Defendant
knowingly requested the funds at issue and/or knowingly and voluntarily accepted the
benefits bestowed.
13. It would be inequitable for this Court to allow Defendant to retain the benefits of the
funds or to be unjustly enriched at the expense of Plaintiff or allow Defendant to retain
the value of the funds at issue without repaying Plaintiff the value of same.
14. In accordance with the law, there is interest due at the highest statutory rate per annum
permitted by law from August 31, 2001.
WHEREFORE, Plaintiff demands judgment against Defendant in the sum of
$8,157.79 together with accruing pre judgment interest at the highest statutory rate per
annum permitted by law from August 31, 2001, and costs of this action.
Respectfully submitted this 2? day of De -P . , 20 6(? .
Helene B. Raush
Bar No: 60140
Stewart & Associates, P.C.
P.O. Box 2629
Suwanee, GA 30024
(866) 990-9968 phone
(678) 684-4975 fax
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.CS § 4904 relating
to unworn falsification to authorities, that he/she, LISA MCGRAW, is duly authorized to
execute this affidavit on behalf of the Plaintiff, CREDIGY RECEIVABLES INC. The Affiant
has reviewed the business records of the Plaintiff kept in the normal course of business, as
pertaining to Defendant, REBECCA P ASH, and the facts set forth in the foregoing Complaint
are true and correct based on information and belief.
CREDIGY RECEIVABLES INC.
BY• Y D te: December 19, 2006
I- Lisa McGraw, AFFIANT
EXHIBIT A
DISCOVER:
CLASSIC
1MPORIIANT INFORMATION
ABOUT YOUR ACCOUNT
CARDMEJMSE'ti AGRP3MENT
The terns and conditions of yow Account, indudirig
how we calculate finance charges, our fees and an
Arbitration of Disputes secborr..... SEE PA GES I - I I
PRIVACY POLICY
A summary of the persomi Information -we collect,
when it maybe shared with others, how we safeguard
the conlii6entialiity acrd security of infomr2tion and
the steps you may take to limit our sharing .of such
inioormaiion with others ......... SE PAra 12 - t3
131L1NG RIGHTS
Jmportainf Information about your rights and our
responsibilities under the fair Credit Bining Act .. , , .
.......................... 5aPAGES 13- 76
CASHSACK BOIJUS' TZIMS AND CONDJIIONS
The terms and condition's of the Cashbark Bonus*
award program, including a desorption of how we
calculate the award and how it is paid .......... , ,
............................. SEE PAGES 76 - 18
CSMFICATx OF INSURANCE
The terms and conditions of the Scheduled Air Travel
Accident Insurance that is provided at no t barge to
you when you use your Card to purchase amine
tickets ....................... SEE PAru 78 - 20
CARDMEMBER AGREEMENT
Plaase read this Agreement rare}ully before using your
Discover' Card Account it come ns the terms and
conditions of your Account some of which may have
changed from earlier materials provided to ygu, !n the
event of any eMerences, this Agreement shall oontroL
We respect your privaT See the Privacy Section on page a
and our Privacy Polity for additional Information.
The Arbitration of Disputes Section on page 10 Includes a
waiver of a number of fights, including the right to a jury
trial.
CARDMEMBER AGREEMENT
Agreement Terms .................. ........... 2
Acceptance of Agreement ....................... 2
Use of Your Account ........................... 2
Authorized Users .............................. 2
Unauthorized Use ............................. 2
Credit Limit-Avallable Credit ..................... 3
Promise to Pay .. ... ....................... 3
Monthly Billing Statement ....................... 3
Monthly Payment options ....................... 3
Minimum Monthly Payment ..................... 4
Cmdk Balances. ............................... 4
Balance Transfers .............................. 4
PlnanFe Charges . ............................ 4
Periodic Finance Charges . ......... .......... 3
Cash Advance Transaction Fee Finance Charges ...... 7
Salance Transfer Transaction Fee Finance Charges .... 7
iriinhurn Finance Charge ....................... 7
Returned Check Fee. .................. 7
ReWmed Discover Card Check Fee ................ 7
Stop Payment Fee ............................. 7
Late Fee. .................................... 8
Pay-by-Phone Fee .............................. 8
Research Fee ................................. s
Overlimit Fee .................................
Defauky4a-elerat3on-Calfettion Costs ............. .
Cancelia'Non ..................................
Privacy ..............................
Credit Authorizations .......................... 9
Change of Terms ..............................
Change of Address .. ....................... T
Assignment of Account ........................ Y
Arbitration of Disputes ........................ 1
Cornpilance wkh Interast Rate limitations .......... 7
Governing Law ............................... 1
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02001 01smar Bank, Member F= 9040DfJW
AGREEMEUT TERMS. The word 'Account' means your
Discover Card Account The word 'Card' means any one or
more Discover Cards issued1n you ar someone else with your
authorization. The words .'you'.. your", or 'yours' refer to,
In addition to-you, the Cardmember, any other person or
persons who are also cantraaually liable -.under: this
Agreement. The Jwords'we', 'us' and'our' refer w Discover
Bank, the issuer of your Discover Card. Thewords'Authorized
user, mean any person whom you authorize to use your
Auamt or a card, whether you notify us or not, The words
"Pricing Schedule' mean the document accompanying your
Card and listing the Finance Charge rates that apply to your
Account The Pricing Schedule is part of this Agreement
ACCEPTANCE OF AGREEMEAT The use of your Account or a
Card by you or an Authorized User, or your failure to cancel
your Account within 30 days after receiving a Card, means you
accept this Agreement, including the Arbitration of Disputes
provision on page 1D.
USE OF YDUR ACCOUNT[ Your Amount may be used for,
• Purchases - to purchase or lease goods cr services from
participating merchants by presenting. your Card or Account
number.
• Cash Advances - to obtain cash advances from participating
automated teller madhinim finandal institutions or .other
locations, or by means of checks which we may furnish to
you, all in accordance wft .such addtfonal tenths and
conditions as may be imposed horn time to time.
• Balance Trarsfers - to transfer balances from other creditors
or to make othertransealons by means of balance transfer
coupons or checks, in accordance with such additional terms
and conditions as we may offer from time to tine.
In addition, your Amount may be used to guararrme
reservations at participating establishments. You will be liable
for guaranteed reservations that are not canceled prior to the
timt specified by the establishment.
Your Account may be used for personal, family, household
and charitable purposes. Your Account inay not be used to
obtain loans to purchase, tarry or trade in securities, or to pay
any amount you owe under this Agreement ('Prohibited
Traruacdons'). Prior to'Its use, each Card must be signed by
the person to whom It Is Issued. we are not responslble for
the refusal of anyone to adept or honor a Card or to accept
checks that we have provided yon. You must return any Card
or unused checks to us upon request
AMOR1ZED USERS if you want to cancel the authority of a
current Authorized User to use your Account or a Carrdd you
must nodfy us in writing err by telephone and destroy any
Card in that person's possession. None of your rights under
this Agreement (tither than to pay amounts owed) may be
exercised by any person not a party to this Agreement acting
pursuant to a power of attorney, without our separate
written agreement (which We are not obligatedto give).
UNAUTHORIZED USE. If a Card is Post or stolen, or if you think
that someone is using your Account or a Card without your
perml%lon, notify us lmmediately. You can notify us by
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teiepimning 1-1100-DISCOVER (1-1IDD-947-2683), or by writing
DISCOVER CARD, Po Sax 15156, Wilmington, I)E-19E86-1002.
You agree to assist us in determining the facts relating to any
theft or possible unauthorized use of your Account or a Card
and to comply with Stich procedures as we may require in
conrxclion with our irrrestigation.
Cum umrT-AVAILABLE CREDIT- We•wiil advise you of your
Account credit limit We may impose a lower limit-that will
apply to cash advances, referred to as the cash advance uledit
limit You agree not to allow your unpaid balance, including
Finance Charges and ieas,-w exceed your Account credit limit
if you exceed your Account credit limit, we may request
immediate payment of the Vraount by which you exceed your
Account credit limit
we may Incmase or decrease your Account credit limit or your
cash advance credit Amit without notice. The credit available
for your use may, from tirneao- ime, be less than your Account
credit limit. For purposes of determining your availabie vedlt,
we reserve the right w postpone for up to 15 business days
reducing your unpaid balances by the amount of-any payment
that we receive. Your available credit will not be increased by
the amount of any credit balance.
PROMISE'TO PAY, You agree to pay us in US Dollars for all
purchases, cash advances and balance transfers including .
applicable Finance Charges and other charges or fees,
incurred by you-or anyone you authorize or permit to use your
Amount or a Card, even if you do not•notNyus that others are
using your Actourd or a Card. We will convert purchases and
cash advances made in a foreign•currency to.US. Dollars at a
rate existing on the date of conversiom if you may us in other
than U.S. DDllars, we may refuse-to accept the payment or
charge your Amount our cost to convert ym r. paymesrt 1a US.
Dollars. A I checks must be drawn on funds an deposit in the
U.S, You may not use a cash advance check, balance,trareer
check or caupoil or any other promotional check dravm on
any Discover Bans: Credit card account to make payments on
your Account.
If your Account Is a Joint Account, each of you agrees to be
liable Individually and Jointly for the entire amount owed an
your Account. We can accept late paymenz3 or partial
payments or checks and matey Orders marked 'payment in
full" or with any other restrictive endorsement without losing
any of our-rights under this Agreement
MONTHLY BILLING SATEMEX. Unless we waive our right-to
do so, we will send you a billing statement after each monthly
billing period in which you have a debit or credit balance of
S1.Do or more. The-billing statement will-show all pwchases,
cash advances, balance transfers, Finance Charges and other
Charges or fees and all payments- or other credits pasted to
your Account during the billing period, it will show your New
Balance, Minimum Payment Due and Payment Due bate.
MONTHLY PAYMENT OPTIONS. You may at any time pay the
entire New Balance shown on your billing statement, but each
month you must pay at least the Minimum Paymerrt Due All
payments must be mailed or delivered so us in Delaware at
-3-
Discover iartiti PC Box 6011, Dover, DE 199034011 or byusing
the ertrelope enclosed with such statement. We will apply
payrnena and credits to the New Balance shown. on your
current %%ing statement in order of the Annual Percentage
Rate applicable to the balance of each transaction category,
from lowest to highest beginning with the balance subject to
the lowest Annual Percentage Bate. We then apply paytneritt
and credits to any new transaction, using the same method.
Hovgeeve; we have the right to apply payments and credits to
balances with higher Annual Percentage states prior to
balances with lower Annual Percentage Rates, such as when
there are two inftfal special rates applicabte to your Account
and the lower Annual Percentage Rate will expire before the
higher Annual Percem9e Rate.
mimmuM moNTHLY PAYMENT. The Minimum Payment Due
eaci month will be the sum a( any amount past due and the
minimum monthly payment The minimum.monthly payment
each month will be the greater of S10.DD or an amount equal
to ibM al the New Balance. rounded to the next higher
whole dollar amount. However, H the New Balance Is less than
S 10.0%, the minimum monthly payrnem will be the amount of
the New Balance. Paying the Minimum Payment Due may be
insufficient to tiring your Account balance below your
Account cred}t limit and, consequently,' may rot avoid the
imposition of the Dverfirnit Fee described in the Overfimii Fee
section.
CREW. HALAIKES. WE will refund any credit balance withO
seven business days from receipt of your written request if
you do not request a rentnd, ive will automatically refund
credit balances greater than 51.00 which remain in your
Acwx%aftw.iwo billing periods.
BALANCE TRAN5FRR5. We may periodically offer you the
opportunity to transfer balances from critter creditors or to
make other transactions to yourAccount by means of'balance
transfer coupons or chedm Each offer will contain an Initial
special rats, which will be the Annual Percentage Rata that
will apply to transferred•balences frsrthe time period spedr7ed
in the offer and may contain a Balance Transfer Transaction
Fee Finance Charge for eacfrbalancetransfer made during the
term of the offer, as disclosed in the offer: After the expiration
of this time period, the Annual Percentage state that applies
for purchases will apply to transferred balances. Balance
transfers subject to the initial special rate are referred ta.as
special rate balance transfers balance transfers for which the
initial special rate has 4wpfred are referred to as purchase raft
bat-am transfers. Each offer will contain an expiration datu_
if you attempt to transfer balances by means of a check after
the expiration, date, we wUl treat the transaction as. a cash
advance. We will not make balance transfers attempted by
means.of a coupon after the expiration date.
ANANCE CNAAGES. You tail avoid payment of Periodic
Finance charges on newpurchases ifyou pay the New Balance
shown on the billing statement on which the purchase fn-st
appears by the Payment Due Date, and the Payments and
Credits on that Statement equal or 'exceed your Previous
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Balance: We all this the `grace. period." You do not have a
grace period on balance transfers m cash advance6 Periodic
Finance.Cnarges are imposed on new balance transfers and
cash advances beginning with the date the transaction occurs.
PERIODIC FINANCE CHARGES. Periodic Finance Charges are
imposed on all transactions until the date of repaymerrL
Repayment means payment of your entire New Balance_
However, if you pay the New Balance shown on the current
frilling statement by the Payment hoe Date, and the Payments
and Credits shown on this statement equal 'or exceed the
Previous Balance, we will nat impose. Periodic Finance Charges
on new purdhasak that is, purchases first appearing an the
current statement Otherwise, you will receive a billing
statement the neat month that includes Periodic Finance
Charges imposed until the date of. repayment
Wo compute Periodic Finance-charges each day for purchases,
cash advances, and balance transfers ("ich we refer to as
transaction categarfes) by using the following equation;
Average Daily Balance x number of days in the bailing period
x Daily Periodic Rate. (You may refer to the finance charge
summary an the frost of your billing statement for these
amounts.) Then we add all the Periodic- Finance Charges -for
each transaction category to get the total. Periadic Finance
Charges farywAErount fheAverage Dail, lMlanceisshown
ab 29PD if no Periodic finance Charges appfy10 the balance Jr)
a transaction category.
We use the twacyde average daily balance pncluding new
transactions) method of calculating the balance upon which
we impose Periodic Finance Charges.'Tttis means if you did not
pay the New Balance shown on the billing statement you
rer,eived during the pa idom biting period by the ?ayrnent
Due Date, we will impose Periodic Finance Charges gn_ngw
purchases that first appeared on that billing statement, as
well wi new purchases that 1rnt appear on the current billing
statement, unless the already unposed- Periodic Finance
Charges on t'ne purchases on your previous billing statement
We compute the average daily balance for each transaction
category by adding up-a)) the dally balances-in a billing period
for a transaction category and dividing the tunal by the
number. at-days in the billing Cycle. We compute the daily
balance for each transaction category on each day by nest
adding the following to the previous day's daily balance.
transactions -made that day, fees. cbacged that day and
Periodic Finance Charges accrued on tha previaw.oay's. daily
balar= one my then suotracting arry credits- and paymerrts
trial are applied against the balance of the transaction
categor)t on that day! in calculating the daily balance for the
previous billing period, we consider the 'previous day's daily
balance' to have been, zero on the first day of the billing
period.
$pedal rate balance transfers and Balance Transfer Trans:
action Fee Penance Charges are included in The daily balance
of the balance transfer transaction category. Balance transfers
that were subied to .an igitiat special rate that has been
terminated due to a late payment are also included in this.
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category until the initial special rate otherwise would have
expired. in calculating the dally balance of the balance
transfer transaction category w the first day of tire billing
period, we wbvact. the unpaid balance of those Balance
Transfer Transanion Fee Finance Charges and balance
translersthw become purchase rate balance transfers on that
day and we add that unpaid balance to the balance of the
purchase transaction category.
All fees charged to your Account are added in the purchase
transaction category wlth the exception of Cash Advance
Transaction Fee Finance Charges which are added to the cash
advance transaction category and Balance Transfer
Transaction Fee finance Charges which are added to the
balance transfer inimnion caregaty, if a transaction is
posted to your Account after the dose of the billing period in
which it occurs, we will treat the transaction as having
occurred on the first day of the billing period in which it is
posted to your Account.
IT) Rate Plans
The Daily Periodic Rate and corresponding Annual Percentage
Rate that apply to each ti nsacdon category is either is fixed
rate or a variable rate) asset forth in your Pricing Schedule.
The Deily Peraodic• Rate -is- 1/365th of the corresponding
Annual Percentage Rate. The variable Annual Percentage
Rate for a vansaction category is determined by adding a
specified "Mow of pereariuse pdt% to the Prime Rate. This
is shown on the Pricing Schedule as "Prime + (percentage
points}.' For purposes of this Agreement, the Prime Rate is
fire highest rate of interest listed as the 'prime rats' in the
money rates section of The "J Street Journal on the last
bus;chess clay of the month. The Prime Rate is merely a pricing
trhdex and don not represent the lowest or bee, interest rate
available to a borrower at any bank at any given .time. Your
ecrease when the
Anna) Percentage Rate will increase or decrease'
prime Rate changes. This change oil! be effective beginning
= the first day of the billing period that belpins during the
month immediately following the change in the Prime Rata
(?) Annual PeMentage Rate for PuroSases
we may have offered you an introductory rate an purchases.
Time introductory rate is the Annual Percentage Rate that will
apply is purchases for the time period specified in the offer.
Attu expiration of this time pxrfgd, the Annual Petcerrtage
=V or pases will apply. fie Daily Perfadit Rates and
onding Annual Percentage Rates in eifeR on the date
this Agreement is furnished to you are set forth in the Pricing
Schaduk
(3) Annual PArteritage Rate for Lash Advairces
The Daily Periodic Rats and corresponding Annual Percentage
Rate in effect an the date of this Agreement Is furnished to
you are set forth in the Pricing Schedule.
(d) Annual Percentage Rate lonBalance Transfers
The Daily Periodic Rate and corresponding Annual Percentage
Rate in effect for special rate balance trdnsfers will be set
forth in the offer from.n s undo which you make the balance
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transfer. As indicated in the Balance Transfers Section above,
purchase rate balance transfers will be subjea to the Gaily
Periodic Rate and corresponding Annual Percentage Rate that
apply to purchases.
The Daily Periodic Rate and corresponding Annual Percentage
Rate in afied on the date tfiis Agreement is furnished to you
are set forth in the Pricing Schedule.
CASH ADVANCE TRANSACWN FEE FINANCE CHARGES. We
will charge you a Cash Advance Transaction Fee Finance
Charge of 356 of the amount of each new cash advance, There
is a minimum Cash Advance Transaction fee FINANCE CHARGE
of 55.00 and no maximum Cash Advance Transaction Fee
FINANCE CHARGE. 'The imposition of Cash Advance
Transaction fee Finance Charges may result in an Annual
Percentage Rate for cash advances that is higher than the
nominal Annuai Percentageitate. All iomis al cash advances,
including the use of Discover Card checks, regardiess of the
purpose for which used, are subject to Cish Advance
Transaction Fee Finance Charges. To obtain the tarn{ finance
Charge an cash advances for each billing period, we add any
Cash Advance Transaction Fee finance Charges for the billing
period charged under this Section to any Periodic Finance
Charges calculated under the Periodic Finance .Charges
Section for the cash advance transaction category.
BALANCE TRANSFER TRANSACTION FEE FINANCE CHAR Cv3. If
the balance transfer offer you . receive Wntairns a Balance
Transfer Transaction Fee Finance Charge, We WdI charge you a
Balance Transfer Transaction Fee Finance Charge for. the
amount of each balance transfer made under that affer. The
imposition of Balance Transfer Transaction Fee Finance
Charges may result in an Annual .Pertetnage Rate for haiante
transfers that is higher than the nominal Annual Percentage
Rate. To obtain the total Finance Charge onbafarue transfers
for each billing period, we add any Balance Transfer Trans.
action fee Finance Charges for the billing period charged
under this Secdon to any Periodic Finance Charges caieulated
under the Periodic Finance Charges Section for the ba;ant;e
transfer transaction category,
MINIMUM FINANCE CHARGE: We will charge you a minimum
FINANCE CHARGE of 5.50 for any billing period in which some
FINANCE-CHARGEof less than 5.50 would otherwise be
imposed.
RETURNED CHECK FEL We will charge you a Returned Check
Fee of S25.W each time you pay i s with a check that is
returned unpaid. This fee wiil•alsa apply if a debit transaction
to a deposit %tco unt from whiidr.you have authorized. is in
writing to periodically deduct all or a part Of an amourrt you
owt us under this Agreement is returned unpaid. We. wilt
charge you this teethe first time any -payment is returned
unpaid even If It is paid -upon resubmission.
RETURNfo DISCOVER CARD CAECK FM We will charge you a
Rewmed Check fee of Sa.01each time we decline to honor
a Discover Card cash advance check :balance transfer check or
other promotional check.
STOP PAYMENT FEE. We may charge a Stop Payment Fee of`
-7-
S15.00 each time we stop payment at your request on a cash
advance check balance transfer check, or other promotional
check.
tATE FEE. We will charge you is late Fee of ;23.0 each time
that, as of the Payment Due Dace, you have fa(led to make the
Min'arwm Payment fore that was required to be paid by that
date.
PAY 8Y PHONE FEE. We may from time to time allow you to
make payments by authorizing us over the telephone to
transfer or pay funds from a deposh account to your•Acmunt
We wili charge a Pay-by-Phum Fee of 510 for each such
transfer or payment of less than 51,500.
RESEARCH FE'c. We may charge you a Research Fee of S5A0
for eacb copy of a billing statement or sales slip that you
request However, we will. not charge a fee if you -request
copies in connection with a billing error.
OVEROMM FEE. We wAJ chargeyoa an Dverlimit Fee of .29.00
each time that, as of the close of is billing period, yaw
ouvianding Account balance exceeds your Account credit
limit This tee may be charged even If the transaction which
causes you to exceed your Account credit limit is authorized
by us or if you exceed your Account credit limit due to the
posting of Finance Charge or fees to your Amt ont.
DvAuLT-ACCELERAnON-COLLECTION COSTS. You are ih
defauft if you become insolvent; If you file a bankruptcy
petition or have one nledagaJnst you; 1f we have a reasonable
belief that you are unable or unwilling to repay your
obligations to us', If you are dedared incornpetent by a court
or if a court appnird s a guardian for you or a conservator for
your assets;, If you die; or If you fail to comply with the terns
of this Agreement, including 'failing to make a required
payment when due, exceeding your Account credit limit, or
using your Card or Account for a Prohibited Transaction. If you
are in default, we may dedare the entire balance of your
P,crourrt-immediately e.and payable without notice. if we
refer the collection of your Amount to an attarney or employ
an attorney to represent us with regard to recovery of money
that you owe us, we may charge you reascrrab)e attorneys'
fees and court or adier. erection costs.as permitted by law
and as actually incurred by us. We may delay enforcing or not
enforce any of our AgInIs Under this Agreemenrt wychout
losing or waiving any of them.
CANCELLATIOtA. tau may cancel your Account by notffyhtg us
in writing or by telephone and returning or destroying every
Card and unused check 'hat we have.prtruided you. of course,
you will stir( be responsible to pay any amount you awe us
according to the terms of this Agreement. If your Account Is a
jamt Accaurd. each of you may cancel your Amount. We may
cancel or suspend your Account at any time without notice.
We may choose not to renew your Account (beyond the
expiration date shown on the face of a Card) without notice.
PRIVACY. We respect the privacy of Information about you
and your Account Orir Privacy Policy induces a summary of
the personal information we coffecc, when it may be shared
with others, how we safeguard the confidential ty and
^B"
security of information and the steps you may take to limit
.our sharing of such information with others. Please read it
carefully as it is part -a) your Cardmember Agreement. As
indicated in our Privacy Policy, we' may report to credit
reporting agencies and other creditors the status and
payment history of your Account, including negative credit
information. We normally report tc suds credit reporting
agencies each month. 11 you believe that our report of your
Acown status L inacturate W incomptete, please write us at
the following address: Discover Card, PO Box 15316,
Wilmington DE 19850-531& Please indude•yotsr name,
address, home telephone number and Account number.
We may from time to time review your credit, employment
and income records. Our-personnel may listen to or record
telephone calls between you and our representatives in order
to evaluate the quality of our service to our Cardmembers
without notice to you. We may use automated telephone
equipment or prerecorded telephone calls to contact you
about your Account. We provide. various rnethnds by which
you can obtain information about your Account We will only
release such information to you, any Authorized User that our
records indicate is an authorized buyer on your Account, and
any other person-with your prior permission, in addition to as
provided in our Privacy • Policy ar as required by law. Our
security measures cannot insure against un;uthortzed
Inquiries. You agree that we will not be responsible for the
release of information to anyone who, even if without your
authorization or permisslon, has gained possession of a Card
ar has leaned other identifying characteristics aboutyou such
as your parsons! identification number, Accaurit number or
social securty numbat
CREDIT AUTHORIZATIONS. Certain transactions will require
our authorization prior to completion of the transaction. in
some cases, you may be asked to provide Identification. f f otA
authorization system is not working, we may not be aisle to
autharlL° a transaction. We will not he liable to you if any cf
these events happen.
CHANGE OF TERMS. We may change any Tenn or part of this
Agreement, including any finance charge rata, fee or method
of torn pudng any balance upon which the finance charge
rate is assessed, or add any new term or part to this
Agreement by sending you a written notice at Itast 15 days
before the change is to become effective. We may apply any
such thangs tg the. outstanding balance 4t yout Account on
the effective date of the change and to new. charges made
after that data. 11 you do not agree. to the change, you must
notify us in writing within 15 days after the mailing of the
notice of change at the address provided 'in the notice of
change, in which case your Account will be dosed and you
must pay us the balance that you owe us under the existing
terms of the unchanged AgreerrrenL Other-Ise, you will
have agreed to the changes In the notice. Use of your
Account after the effitfve date of the change will be
deemed acceptance of the new terms as of such effective
date, even If you previously notified us that you did not
agree to the change.
_g_
CHANGE OF ADDRESS If you change your address you mull
notify us gf your new address within 13 days,
ASSIGNMENT Of ACCOUNT. We may sell, assign or transfer
your Account or any portion thereof without notice to you.
You may notsell, assign or transfer your Account without first
obtaining oLr prior written consent
ARBITRATION OF DISPUTES. In the evenl of any past, present
or future claim or dispute (whether based upon contracL tore,
statute, common law ar equity) between you and us arising
from or relating to your Account, any prior account you have
had wtth.us, your application, the relationships which result
from your Account or the enforceability or scope of this
ariiintation provision, of (fie Agreement or of "y. prior
agreement, you or we may elect to resolve the claim or
dispute by binding arbitration.
IF EITHER YOU OR WE ELECT ARBITRATION, NEITHER YOU
NIP, WE SHALL HAVE THE RIGHT TO U7IGATE THAT CLAIM IN
COURT OR 70 HAVE A JURY TRIAL ON THAT.O .AW. PRE-
HEARING DISCOVERY RIGHTS AND POST-HEARING APPEAL
RIGHTS wits. RE LIMITED. NEITHER YOU NOR WE $HALL BE
ENTITLED TO JOIN OR CONSOLIDATE CLAIMS IN ARBITRATION
BY OR AGAINST OTHER CARDMEMBERS AMTH RESPECT TO
OTHER ACCOIJNT5, OR ARBITRATE ANY CLAIMS AS A
REPRESENTATKM OR MEMBER OF A CLASS OR 114 A PRIVATE
ATMRNEY GEWFAL WAOTY. Even if all parties have opted
to litigate a claim in court, YOU or eve may elect arbiiravon
with respect to any Claim made by a new party or any new
Claims later asserted in that lawsuit, and nothing undertaken
therein shall constitute a waiver ai any rights under this
arbitration provision.
We will not invoke our right to arbitrate an. individual claim
you bring in small claims corm or your. state's equivalent
court, if any, so long as the claim is pending only in that court
and does nut exceed SS,DMDD,
Your Account )nvolves interstate commerce, and this provision
shall be governed by the Federal Arbitration Act (FAA). The
arbitration shall be conducted, at the option of whoever riles
the arbitration clafm,'by either JAM&Indispute UAt+AS) or the
National Arbitration Forum iNAF) In accordance with their
procedures in effect when the claim is filed. For a copy O: their
procedures, to isle a daim or for other information, contact
JAMS at 192111 Main Street, Suite 3DO, Irvine, CA 92514 (phone
14004wlsw) or RAF at P.O. Boa 50191, Minneapolis, MN
55405 (phone 1-80"74-2371). At your written request, we
will advance any arbitration filing, administrative and hearing
fees whicli you would be requiredto payto pursue a Claim m
dispute as a result cif our electing to arbitrate that claim or
dispute. Send requests to P.O. Box 95152, Wilmington, DE
19836-1020. Tfte arbitrator will decide who will ultimately be
responsible for paying those fees. In no event will you be
required to reimburse us for any arbitration filing,
administrative, or hearing fees `fn an amount greeter then
what your and our combined court costs would have been if
the claim had been resolved in a state court with jurisdiction.
-10-
Any arbitration hearing will rake place in the federal judicial
district where you reside. The arbitrator shall foflow
applicable substantive law to the extent consistent with the
FAA and applicable statutes of limitations and she)) honor
claims of privilege recognized at law. If requested by arty
party, the arbitator shalt write an opinion containing the
reasons for the award, The arbitrator's decision will be final
and binding except for any appeal rights under the FAA and
exceptthal if the amount in cornroversy exceeds Iion,DDO.DD,
any party may appeal the award within all days to a thtse.
arbitrator panel which shall review the award de novo. The
costs of such an appeal shall be borne by the appealing party
regardless of outcome. Judgment upon any award by the
arbitatot. may be enforced in any Court having jurist iciron.
Our rights and obligations. under this arbitration provision
shall inure to tlx benefit of and be binding upon our parent
corporations, subsidiaries, affiliates (including, wtthcut
limitation, Discover Finandai Services, Inc.), predecessors,
successors, assigns, as well as the officers, directors and
employees of each of these entities, andwill also inure to the
benetTt of any third party named as a co-defendant with us or
with any gf the foregoing in a claim which is subject to this
arbitration provision Your right; anti obligations under this
arbitration provision shall inure to the benefit' of and be
binding upon all persons cony, ractuafly liable under this
A reement and all Authorized Users of the Account. -This
arbitration provision shall survive termination of your
Account as well as voluntary paymerst in full by you, any legal
pproceeoings by us to collect a debt owed by you, any
bankruptcy by you and any sate by us of your Account-
COtBPUANCE WiTh-INTEREST 0ZE WAITAMONS. We intend
that this Agreement will comply with applicable interest rate
limitations You will not be required to payFiaance Charges or
other charges at -a rate that is greater than the maximum
amount permitted by taw. If it is ever finally deterrrdned that,
but for this Section, the France Charges or other charges
under this Agreement would exceed the rr=lmum lawful
amount, the Finance Charges and other charges will be
reduced to the maximum lawful amount. Any excess amount
that you have aiready paid will be used to reduce the out-
standing balance of your Account or will be ?efundid to you
by mearts of a check in our discretion.
GOVERNING LAW. This Agreement will be governed by the
laws of the State of Delaware and applicable federal laws. if
any part of this Agreement becomes unenforceable, it will not
make any other part unenforceable.
Distver Sank
DISCOVER CARD
Ro'-1-I
Vice President
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PRIVACY POLICY
We Aespe>:t Your Privacy
our mission is to provide you with superior products and
services, along with the peace of mind knowing that yaw
privacy is secure. We understand your concerns about
..emg information about you and your Account. We want
to assure you that we have taken steps, and will continue to
take steps, to safeguard that lniormation.
This Privacy Policy describes our efforts to meat these
objectives. h includes a summary cd the personal information
we 91'at, when it may be shared with others, how we
safeguard the confidentiality andsecurhy of iniom"ars, and
the seeps that you may take to limh our sharing of such
information with others. Please read h carefully. We hope our
privacy Policy vrili help you understand Iwo we collect and
share Information.
t. WHAT PERSONAL INFORMATION DO WE COLLECT?
70 serve you better and manage our businesy it is important
that we collect and maintain accurate personal information
abort eyaauu, we obtain this Information from applications and
orherfi4% you subrahto us, *13111 your dealings with us and
other, from consumer -reporting agencies, and from other
sources, such as our Web sires. For example,
• We rosy obtain information such as your name, address and
dace of birth from applications and other forms you submit
to Ls.
• We may obtain information such as Account balances,
Payment history. your use of your Account and the types of
services you prefer from your transactions and other
dealings with us and others
• We may obtain information such as the balances of your
loans with other lenders and your payment history with
others from consumer reporting agencies.
• We may otrtain information such as your irrtemet service
providr.C your domain nanht, your computer: operating
system and Web browser, your Web site use and your
product and service preferences from your visits m our web
sites.
Z IS PEr7SONAl. INFORMATION SHARED WITH OTHERS?
we limit the sharing of information with others Many of the
offers you receive ern •praducls and ssavices are Provided
directly to you from us. For example, a retailer that accepts
the Discover' Card may come to us with a special offer for
Cardmembers, such as. a discount certificate or product
upgrade. After careful eorssideration of the nature of the
alter and the company'-wt will create a list of Cerdmembeis
who may be interested in the offer based on terrain
characteristics. We will send the offer directly to those Card-
members on behalf of the retailer t% for example, including
an insert in their monthly bili'Sng statement or mailing the
offer ourselves we control the information used to make the
offeg we do not share the list or any personal information
wbhthe retailer.
There are, however, circumstances in which we may share the
information we collect about you, as described in Section 1.
with other companies in order to•provide you with access to
products and services and to service your Account effectively,
as detailed below. We require these companies to adhere to
our privacy standards and to use this Information only for the
limited purpose for which it was shared. We do not allow
them to disclose 11 to other, without our prior approval.
a, sharing Personal information- with Our Corpome,;FarriRy
We are pan of the Morgan Stanley Dean Witter -family of
companies. Our corporate family offers a wide variety of
producrsand services thai can help you manage your finances.
In order to provide you with amli% tc, these products and
services, we may.share the information we collect about you,
as described in Section 1, with other members of our
corporate family. These companies -include financial service
providen tflat crifer mortgage lend'mg services. securities and
asset managemerri. services, imiestmert opportu irties and
mutual funds, and may include runt-nnancia! service providers
in the suture as our corporate family torninues to grow.
b. Sharing Personal Information with Nan Affifrared Parries
for Marketing Purposes
we may share the information we calleC' about you, as
described in Sedan 1, with non-affriiatsd third parties,
including those that accept the Discover Card, in order to
provide you with access to producrs ,and services affere:d
directly by these companies that may be of value to you.
These companies include financial service providers, such as
lnssrante tonipanie; and nonfinancial companies, such as
retailers.
c Sharing Personal information with Otherv
We may share the information we collect about: you, as
dscrlbed in Section 1, with companies that perform wpport
or marketing services an our behalf, such as mailing, market
research and data-processing; other financial institutions with
which we stave joint marketing agreements or companies
that are our panne for cobtend cretin card programs or
reward programs. We may also -share such Information as
permitted by law.
3. HOW DO WE PROT517i THE CONFIDEMIALrN, SECURITY
AND INTEGRITY OF INFORMATION A$OUT'loU7
We maintain physical, electronic and procedural safeguards to
protect the irfiorrnation we collect about you. Access to such
h$ortnariorii5 restricted to indWsduaisaruho need }tin order to
seryice your Account or provide produces and services to you,
and who are trained In the proper handling of such
information. Employees who violate these confidentiaiity
requirements are subject to -our disciplinary process. Where
third parties provide support services, vde require their 'to
conform to our privacy standards.
tt is important that the information we maintain about you is
accurate and complete. If you see information in your
monthly billing statements or elsewhere which suggests that
-13-
our irriormation is incomplete or ina¢urate, please write to us
at Discoveriard, P.D. Box 30%1, 5ah Lake City, 07 8413D-0961
so that we can update this iniormation.
4. HOW CA14 YOU LIMIT SHARING OF INFORMA7 ON ABOUT
YOU7
We respell your privacy and after you choices as to whether
we may share information about you with others. N you
prefer That we not share the in'farmartion we collect, about
you, as described in Section 1, with non-affiliated third panes
or if you prefer that we rat share that information with
companies in our corporate family, you racy opt out, that is,
you may direct us not to share that information, if you
indicate a preference that we do not share that itriorrnation,
please understand that you will not receive offers far products
and services provided by other companies that could help you
lower your COM maximize your financial resources and
manage your finances. To indicate your preferences, call us at
1-8DD-225-5202 or write to us at Discover Card, P.D. Box 3D961.
Saft Lake City, UT 641300961. Your written request should
include your name, address, telephone number and Account
number(s) and should not be sent with 'any other
correspondence. In order to process your request, vue require
that the request be provided by you direcEly.and not through
a third party, You will need to provide us with your
preferences far each credit card account you have with Lm
You may ratify us about your preferences at any time. If you
have previously notified us, it is not necessary to do so again
unless you decide to change your preferences.'Yout request
will remain in effect until you notify us otherwise.. We will
honor your request and oat share the information we collect
about you, except as permitted by law. For example, federal
law permits us to share information about you with consumer
reporting agencies, service providers and marketing partners.
It also permis US to share information about our experiences
and ttarsectlons with you, such as your Account-balance-and
payment hiswry With other members of our corporate family.
If you area new Cardmember, we will not share any
information about you, except as permitted bylaw, for thirty
days after we provide this policy to you, in order to give-you
an opportunity to inform us about your preferencei. if you
are an existing Cardmember, please undersuand that you may
continue to receive marketing afters directly fiom -other
companies that were already in production prior to the
processing of your requesL
Tnls ? ' Poficy is provided to the primary Cardmember
listed on the Account. However, any joint Cardmember has
the right to rxrtif? us about preterencesturid we will treat that
request as appgyrng to the en#ire AttourrL We do not share
information about former customers, except as permitted by
law.
This Privacy Policy is provided to you by Discover Bank and 113
subsidiaries, which currently include GTC Insurance Agency,
Inc It applies to the Discover Platinum, Dismver Gold,
discover Classic and Discover Private assuel Cards, and the
products and services offered 1n connection with those cards,
indud'ing The negister' card registration service (with the
exception of any information registered in connection with
the service; which will not he shared) and the Discover
Exchange payment service. It is part of your Cardmember
Agreement- and provides a further explanation of how we
collect and share irriormation. Please note that you will also
receive privacynvticw for other credit card accounts you have
with us, as well as other financial products and services
provided to you by us and our affiliates. You will need to
indicate your preferences for each of these separately as
disclosed in the notice.
CLPLPIGDM1
Your Billing Rights
KEEP THIS NOTICE -FOR FUTURE USE
This notice contains important information about your rights
and our responsibilities.under the Fair Credit, Billing Act.
1. Nottty Us-in use of Errors or Questions About Your BTU
If you think your bill is wrong, or if yov need more
information about a transaction on your bill, write us on a
separate sheet of paper at the addrea listed on your blli'for
Notice of Billing Errors. Write to us as soon as possible. We
must hear from you no later than 60 days after we sent you
the first brig on which the error. or problem appeared. You can
telephone us, but doing so will not preserve your sights,
In your letter, give us-the following information:
• your name and Account number.
• your dollar amount of the suspected error.
• describe the error and explain, if you can, why you believe
there is an error. If you need more Information, describe ate
item you are not sure about
If you have authorized us to pay your credit card bill
autommicaffy from your savings or checking account; you can
stop the payment on any amount you think is wrong. 10=P
the payment, your letter must reach us three business days
before the automatic payment is scheduled to occur.
2. Your Rights and Our Responsibilities After We Receive Your
W:ft rr Nonce
We must acknowledge your letter within 39 days, unless we
have corrected the error by then. Within 90 days, we must
either correct the error or explain why we believe the hill was
correct
Afar we receive your letter, we cannot try to collect any
amount you question, or report you as delinquerrL We Can
conrtinue to bill you for the amount you question, including
finance dzarges, and we can apply any unpaid amount against
your Account credit limit Yqu -do not have to pay soy
questioned amount while we are investigating, but you are
still obligated to pay the parts of your bill that are not in
question.
-15-
it we find that we made a mistake on your bill, you will not
have to pay any finance charges related to any questioned
amount. H we didn't make a mistake, you may have to pay the
finance charges, and you will have to make up any missed
payments on the questioned amount. In either case, we will
send you a statement of the amount you owe and the date
that it is due.
if you fail to pay the amoum that we think you owe, we may
report you as delinquent. Hovrevet, if out explanation does
nal satisfy you and you write us within ten days telling us that
you stet refuse to pay, we must tell anyone we report you to
that you have a question about your bill. And, we must tell
you the name of anyone we reported you to. We must tell
anyone we MOM you to that'+}te matter'has been settled
between us when it finally is. N we don't follow these rules,
we can't collect the first 550 ai the questioned amount, even
if your bill was correct
a special Ruk For Cree tt Card Purchases
M you have a problem with the quality of goods or services
that you purchased with a credit card, and youaried in good
faith to correct the problemwiththe merchant, you may have
the right not to pay the remaining amount due on the' goods
or services. There are two limitatioru on this right
(a) you muss have made the purchase in your home state or, if
not within your home state, within 100 miles of your current
mailing address; and
lb) the purchase pries must have been more than 550.
These l'msltit tft do not apply (f we oVm a operate the
merchant, ar if we mailed you the advertisement Tor the
goods or services.
DISCOVFRO CARP
CASSBACK $ONU!SO
TERMS AND .CONDMON5
The Cashback Bonus' Terns and Conditions consatute a
separate and independent agreement fmm-the Cardmembw
Agreement and apply to Accounts that participate in the
Lasbback Borws program. However, these Terns and
Conditions are subject to the Arbitration of Disputes section
of the CardmemberAgreamerrt. whichis incorporgted-harem.
1. The Cashback Bonus award is an amount denominated in
dollars and cents whlch may be tamed by Cardmembers by
using their Distovera card for qualified puraltases. A Cashback
Bonus award is not earned for Prohibited Transactions (as
defined in the Cardmember Agreement) cash advances or
balance transfers.
2. Eashback, Bonus payments ate cakutated based on
purdrases made during an annual period corresponding to
tfre ca=mber's anniversary year. The first anniversary year
begins on the date the Lard is issued and ends on the last day
of the twelfth monthly bitting peAcid which follows. Each
-ts-
successive anniversary year is the approximate one-year
period comprised of the next twelve monthly billing periods.
3. ?xcepi as otherwise noted below, the Cashback Bonus
award is calculated by multiplying each purchase by the
applicable percentage rate:
• :s% (Dcs), H the purchase is pan of the slrst 51,DOn in
purchases during the anniversary year,
.50% (.0050}, n the purcnasa is parr of the second 51,DDD in
purchases during the anniversary year,
• .75% (.007S), H the purchase Is part of the third S1,000 in
purchases during the anniversary year,
• 1.)% (.01), H the purchase is part of the purchases in excess
of 53,DDO during the annlvemary•year.
Beginning OA May 1, 20D0, the applicable percentage rate for
all ,purchases made at warehouse dubs during the anniversary
year will be a fixed rate of.25% (.13025). However, these ware-
house dub purchases will continue to be included in the total
amount of purchases made during the anniversary year and
used to determine the applicable percentage rate listed above
for other purchases. Please call 1-800-347-71156 or visit our
Web site at Discovercard.com for a )ist of warehouse clubs.
The total of these calculations for each anniversary year is the
earned amount of the Cashbadk Bonus award, w)tidrt will be
paid as described below provided the conditions contained in
paragraph 4 below are met. The calculation begins again with
the be inning of each anniversary year. The Cardmembers
rnonthgy billing sltement will show the earned amour of
the Cashback Bonus award and total purchases through the
date of the ratement for the current anniversary year. Prior
to actual payment the purchases on which a Cashback Bonus
award Is calculated maybe audited for compliance with these
terms.
4. The Cashhack Bonus award vests and is paid shortly after
each ann)venaryyearto those Cardmembers in good standing
on the anniversary date and at the time of the payment. To be
in good standing, you may not be in default (as defined in the
Cardmember Agreement) and you -may not have vied your
Account for any Prohibited Transactions within the past year.
If an Account is closed for arty reason prior to the anniversary
date, any Cashbeck Bonus award earned by the Cardmember
since the last anniversary date will be forfeited. Cardmerrtbers
who are delinquent at the time of the payment may, at the
option of Discover Card, have their Cashback Bonus award
applied as a credit to their Account.
5. The exact method of payment of a Cashback Bonus award
may change from year to year, but the Cardmember aril
have the opportunity to receive a Cashbar:k Bonus award Ina
ash equivalent (i.e., check or credit to the Cardme:mbers
Account). As pact of the payment method, the Cardmeinber
may have the opportunity to make a choice as to the manner
in which the fashback Bonus award is paid. The failure to
make such a choice on a timely basis may result in the exercise
of default payment options. It is the C:ardmembers respon-
sibikto notify Discover Cord -in the event a •Cashback Bonus
payment Is not received for any reason.
_17-
The Cashback bonus award is paid to qualifying Cardmembers
either by means of a credit to the Account or by a check that
is mailed to the Cardmember in Discover Card's sole discretion,
6. In the event a Card is lost or stolen the earned amount of
The Cashback Bonus award, the amount of qualifying
purchases and the anniversary date irom the old Account will.
be transferred to the new Account
7, Discover card reserves the right to make other adjustment
to Cashbadc Bonus amounts earned based on Account activity
(e,g., a credit to an Account in connecdon with a prior
plrrdrase will result In a redurlion ai the Cashbadc .Eons
award).
& Three terms and conditiom are subject to change without
notice. Changes may he made during a. Cardmember's
anniversary year, and may include but are not limited to,
modifying the level of purchases required to quality
for the various tiers, establishing a maximum amount of
Cashback Bonus award Cardmembers may receive, changing
the type of transactions that constrrrne a purchase, changing
the amount of Cashback Bonus award tarried on certain types
of purchases, imposing additional teWirdWA or terminating
the program.
DESCRiPT10N OF COVEP.A'GE
SCHEDULED AM TRAVEL ACCMWT INSURANCE. Discover'
Classic Cardtnembers are provided with up to 5750,000
Scheduled Air.7ravei Accidenty protection. Whenever you use
your Discover Classic Card fthe'credtt.card') to charge your
entire Common Carrier Fare Ticket on any Commercial Alrtraft
operated by a Scheduled Air Carrier under a license far the
u3nsponation cf-passengers for hire therein called Scheduled
Air Carrier), you autamatimlly receive this valuable coverage
at no additional cost.
Tne benefits of the Policy providing your • coverage are
governed primarily by the law of a state other than Florida.
.Coverage is undetv,irrmen by %at(ona( union Fire Insuratim
company of Pittsburgh, PA (the 'Insurance Cnmpany'), with
offices in New York, NY Certain limitations and exclusions
apply.
PLAN FEATURES
Sarin Amount 5150,DW family Aggregate Principal 5um j
ACCIDENTAL DRAM SENEFK insurance coverage will be
agvaltn-the benisfilamountforaccidents loss ofi'rfe.TheIds
must atom within one year of the accident that caused the
Injury. Family Aggregate Principal Sum means the total
amount of insurance )n iorce on.She CATtimember, his or her
sporae ant} their dependent children for any one accident If
rme than one insured Person em as the resuh of the injuries
receWd in any one accident, the Family Aggregate Principal
Sum will be pro-rated and paid in accordance with the claim
_ 1B_
payment and beneficiary provisions of the Policy. Once the
Family Aggregate Principal Sum is paid for any one Insured
Person in a Family mat occurs as the result of any one
accident rmiurther benefit are payable for further deaths in
that Family due to injuries received in the same accident
"injury" mean,, bodily injury. (a) which is sustained as a din ecc
result of an unintended, unanticipated accident that L
external to the body and that occurs while the injured
parson's coverage under this Policy is In iome, and (b) which
dlrectiy (mdependern of sicknim disease, mernai infirmity,
bodily infirmity or any other causal causes a covered toss.
DISAPPEARANCE BENETITS. We will presume you suffered loss
of Iffe due to an accident if, you are riding in a Scheduled Air
Carrier that is involved in a covered accident and as a result of
the acridem, the Scheduled Air Carrier is wracked, sinks, or
disappear"- and your body is not found within one (1) year of
the accidesst.
The total of all benefits payable for you, your spouse and
your dependent childran from, the same accident will not
axceed the 5]S0;O0 Family Aggregate Prnndpal Sum.
ELIGIBIU[Y. This automatic insurance is provided to etigtbie
holders of the credit card whose names appear on the credit
card, their spouses and their unmarried dependent children
under age 19 fage 23 if attending school on a tu)i-time basis
and fully dependent on you for support)_ However, the age
limit does not.appiy to a child who is incapable of seff-
susraining employment by reason of mental or physical
incapacity.
EFFECTIVE DABS. Your insurance under this plan is efFective
on the later of: 1) July 1, 2001; or 2) the date you become an
eligible person.-Your tnsurance under this plan will cease on
the earlier of. 1) the date the insurance coverage is
terminated or 2) on the dM you cease to be an eligible
holder of the credit card.
THE BENEFICIARY. Unless you designate otherwise with a
benefdary designatian form, your death benefit vAlf be paid,
in equal shares, to the firs surviving class afthcse that follow
(1) your spouse; (2) your children; (3) your parents; or (4) your
brothers and sisters. if no class has a survivor, the beneficiary
is your estate. You may change your beneficiary by writing to
the Insurance Company at Acdderd & H alth Division, 500
West Madison Street, Suite 2250, Chicago, IL SM61.
CWM PROCEDURE. dairn'fatrns MY - be Dbtatned tlrrpugh
the insurance Company, Claims for benefits must be filed with
the insurance Company within 90 days or as soon as
reasonably possible after the lass occurs.
PLAN OF INSURANCE COVERAGE. You, as a Cardmember, and
your spouse and children will be covered against injuries that
result. in an acddertsal dEath while a passenger (not an
operator, pilot; or Grew member) In or on, including getting in
or out of, or on or off of, any Scheduled Air Carrier if the
Common Carrier Fare Ticket for the-flight was charged to your
tsedit card.
_ tg_
Companion tickets issued ftsr free with the -purcha3e o! a fuli-
tare common carrier ticket and used by a spouse or
dependent child will be considered as fully charged to the
credit card, If the corresponding full Common Canier WE
Ticko is-charged to the credit card.
Coverage is effective when you board the Scheduled Air
Carrier, provided the lull Common Carrier Fare Ticket is
purthmij, or the travel Teservatson is made foT the
companion tickets, prior to boarding such Scheduled Air
Larrier. Coverage ends when you alight from the -Scheduled
Air Carrier.
EXCLUSIONS. Benefits are not payable If the loss.is caused by
or resuhs; from; 1) selfti+rfiined injury or sufdde; 2) sickness,
disease. or memtal incapacity or bodily infirmity whether
directly or indirectly, 3) infecdons of any kind regardless of
how contracted, except bacterial infections-that are directly
caused by botulism, ptomaine poisoning or an accidental cut
or wound independent and in.-the absence of any underlying
sickness; disease 'or condition including but not limited to
dabetes; 4) committing or attempting to rxsmmh a felony; or
s) wan or act oY war, dedared or undeclared.
LimiT cons. Seneffts will only be Payable under one Card-
member accourrt, the credit card under which the Common
Carrier Fare Tickets were fully charged.
lieneirss are not payable- for -10M due to injury svstained
whik on a trip fDr V"6 the titkets were WrihiM6 vvydr a
frtwmt flyer uoucirec
Complete provisias perwining to this plan of insurance are
Contained in Policy (79029072 issugd by.National Union Fire
Insurance Company of .Pittsburgh,. PA vvhh offices In New
York, NY. The prem+um for this insurance is paid by Discover
Financial 5er kes,.lnc, out-of income derived tram its-aedtt
cardoperatioriL
Please read this Description of Coverage. Keep It in a sale
place with your other insurance document. -This Descfigdon
of Coverage (Form -dumber 53O3ii5DOQ is not a contract of
insurance but Is simply an informative statement to each
eligible Individual of the principal, provisions Df the insurance
while in effect
tf a conflict exists between a statement ire this •Desaiption tsf
Coverage and any provisions In the Policy, the Policy wiA
govern. claims administered by: A&H Claims Department, P.O.
Box t>7D1, Wilmington, DE 19850.5701, (BOIL 551-DU4.
EXHIBIT B
FIRST SELECT
CORPORATION
ACCOUNT AGREEMENT
Your DISCOVER account has been trand'emed to First Select Co porstim. Your DISCOVER account was closed at the time of this transfer and will therefore continue to be
closed This Account Agreement contains the terms that govern your First Select account (the "Accout'7. In this Agreement "you" and "Your' mean each person who is
liable for payment on the Account "We-our" and'` ui mean First Select Corporation or its assignees. Becausoyour Account has been transferred to us, you are now
obligated to repay the Account to us instead ofDISCOVER. If the,Account was opened as a joint account, we may act on the instructions of any joins. accoum holder.
PaymertslFinance Charges: As long as you have a balance outstanding on your Account, finance charges are calculated as follows.
To figure the finance charges for each billing cycle; we multiply the average daily balance periodic rate: The daily periodic rate we apply is your Account Annual Percentage
Rate divided by 365. The Annual Percentage Rate will be calculated as disclosed in your most recent DISCOVER account term (the "Original Terms'. Ifyour Original
Tams provided for different Anouat Percentage Rate to be applied to differed components of your outstanding balance, we will apply the lowest such Annual Percentage
Rote on your entire outstanding balance
We may accept late or partial payments, or payments marked"paid in full" or marked with other restrictions, without lasing our right to collect all amounts owing under this
Agreement You may ask First Select Corporation to pay yaw Account by debiting your checking or savings account You may reveke your authorization by writing to First'
Select Customer Service.
Fees: We will charge your Account a fee for each billing cycle within which your Accent is delinquent (late charge). The amount of the late charge will be as disclosed in
your Original Turns or the mndmann late charge permitted by the law of your state of residence, whichever is lower,
We will chargeyour Account a fee for each reburied payment check (returned check charge). The amount of the retuned check charge will be w disclosed in you Original
Terms, or the maximum returned check charge permitted by the law or yea state of residence, whichever is lower.
To the extort provided in your Original Temps andto the extent permitted by applicable law, in addition toy our obligations to pay the outstanding balance on your Account,
plus interest and fees as disclosed herein, we may also charge you for any collection costs we incur, including but not limited to reasonable attomey's fees and court costs. If
your `Original Tams provided for an award of attorney's foes and court costs, such provision as incorporated herein shall apply reciprocally to the prevailing party in arty
lawsuit arising out of this Agreement
Nun-Waiver or Certain Rights: We may delay or waive enforcement of any provision of this Agreement without losing our right to enforce it or arty other provision later.
Applicable Law, Severabitlty, Assignment: No matter whereyou live, this Agreement and your Account we governed by federal law and by the law of the state designated
as the applicable law in your Original terms. Ifyour Original Terns did not contain an applicable law provision, tnei this Agreement and your Account are governed by
federal law and the lawofyo r state of residence. This Agreement. is afinal expression of the agreemerdbetween you and us and may not be contradicted by evidence of any
alleged oral agreement. If a provision of this Agreement is held to be invalid or unenforceable, you and we will consider that provision modified to conform to applicable law,
and the rest of tie provision in the Agreement will still be enforceable We may transfer or assign our right to all or some ofyour payments. If stet law requires that you
receive notice of such and event to protect the, purchaser or the assignee, we may giveyou such notice by filing a financing statement with the state's Secretary of State.
Customer Service: For general questions regarding your First Select account, please call our toll-free service number, 1-888-924-2000. For quality assurance purposes, and to
improve customer service and security, telephone calls to or from our offices maybe monitored or recorded.
Credit Reporting: If your fail to fulfill tine toms of your credit obligation, a negative credit repot reflecting on your credit record maybe submitted to a credit reporting
agency. In order to dispute any information we are reputing aboutyour Account, you must write to us at the following address: First Select Corporation, P.O. Box 9104;
Pleasanton, California 94566.
Shading Information: We may share irdomotion with our affiliates, including without limitation. Providian National Bank and Providian Bank However, you may write to
us at arw time instructim us not to share credit information with our affiliates.
YOUR BILLING RIGHTS-KEEP THIS NOTICE FOR FUTURE USE
This notice contains important infmnation about your rights and our responsibilities under the Fair Credit Billing Act
Notify Us In Case of Errors or Questions about Your Bill
If you think your bill is wrong or if you need more information about an entry on your bill write' us, on a separate sheet, at the following address: First Select Corporation P.O.
Box 9104, Pleasanton, California 94566. Write us as soon as possible We must hear fromyou no later than 60 days utter we sent you the first bill on which the error or
problem appeared. You can telephone us, but doing so will not preserve your rights.
In the letter, giveus the following:
-Your name and Account number.
-The dollar amount of the suspected error.
-A description of the error and an explanation, if possible, of why you believe there is and error. If you need more information, describe the item you are not sure about
Your Rights and Our Responsibilities After We Receive Your Written Notice
We must acknowledge your letter withe 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the
bill was correct After we receive your letter, we cannot try to collector repot you as delinquent as to any amount you question, including finance charges. We can apply any
unpaid amount against your credit line. You do not have to pay any questioned amend while we are investigating, but you are still obligated to pay the parts of the bill that are
not in question
If we find that we have made a mistake on your bill, you will not have to pay anyfinancecharge related to any questioned amount If we did not intake a mistake, you may
have to pay finance charges, and you will have to intake up the missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe
and the date that it is due. If you fail to pay the amend we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to
us within 10 days telling us that you still refuse to pay; we must tell anyone we report you. to that you question your bill. And we mist tell you the name of anyone we reported
you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we do not follow time rules, we cannot collect the fast S50 of
the questioned amount even dyer bill was correct
Special Rule for Credit Card Purchases
Ifyou have a problem with th e quality of goods and services that y on purchas ed with your DISCOVER credit card and you have tried in good faith to coirrextthe problem with
the merchant, you may not have to pay the remaining amount due on the goods or services. There are two limitations to this nigh: (a) you must have made the purchase in
your home state or, if not within your home state, within 100 miles of your current mailing address: and (b) the purchase price must have been more than S50. These
limitations do not apply if either we or DISCOVER own or operate the merchant, or we or DISCOVER mailed you the advertisement for the properly or services
EXHIBIT C
ACCOUNT STATEMENT FOR REBECCA P ASH
ACCOUNT MONTHLY BALANCE STATEMENT
SUMMARY
AccountID 10206212 Charge off Balance 8,157.79
Account Provider First Select, Inc. Current Balance 19,523.56
Product Discover Card Open Date 07/30/1992
Product Type Credit Card Charge Off Date 08/31/2001
Account Number# 4168-1000-1943-7134 Last Payment Date 03/15/2006
Account Original ID# 6011-0025-3011-7282 Customer Name REBECCA PASH
APR 18.000% Report Date 12/19/2006
STATEMENT
PERIOD: 08/31/2001 To 08/3112001
Total Principal Interest Expenses
BEGINNING BALANCE 18,157,79 18,157.79 10.00 10.00
I Total Principal Interest Expenses
ENDING BALANCE 18,157.79 18,157.79 10.00 10.00
PERIOD: 09/01/2 001 To 09/30/2001 1
Total I Principal Interest Expenses
BEGINNING BALANCE 18,157.79 18,157.79 10.00 10.00
(Total (Principal (Interest (Expenses
ENDING BALANCE 18,278.48 18,157.79 1120.69 10.00
PERIOD: 10/01/2 001 To 10/31/2001
Total Principal Interest Expenses
BEGINNING BALANCE 18,278.48 18,157.79 1120.69 10.00
ENDING BALANCE
BEGINNING BALANCE
Total Principal Interest
18,405.04 8,157.79 247.25
PERIOD: 11/01/2001 To 11/30/2001
ITotal I Principal Interest
18,405.04 8,157.79 1247.25
ITotal (Principal
ENDING BALANCE 18,529.39 18,157.79
PERIOD: 12/01/2001 To 12/31/2001
ITotal Principal
BEGINNING BALANCE 18,529.39 1 8,157.79
Interest
371.60
'Interest
1 371.60
Expenses
0.00
Expenses
0.00
Expenses
1 0.00
Expenses
0.00
[Total Principal Interest [Expenses l
ENDING BALANCE
BEGINNING BALANCE
8,659.78 1 8,157.79
PERIOD: 01/01/2002 To 01/31/2002
Total`Principal
8,659.78 8,157.79
501.99 1 0.00
`Interest Expenses
1501.99 1 0.00
Total' Principal Interest Expenses
ENDING BALANCE 18,792.17 18,157.79 1634.38 10.00
PERIOD: 02 101/2002 To .0212.8,/2002
1
Total Principal Interest Expenses
BEGINNING BALANCE 18,792.17 18,157.79 634.38 10.00
ITotal Principal Interest Expenses
ENDING BALANCE 18,913.57 18,157.79 1755.78 10.00
PERIOD: 03 /01/2002 To 03/31/2002 1
Total Principal Interest lExpenses
BEGINNING BALANCE 18,913.57 18,157.79 755.78 10.00
ITotal Principal Interest lExpenses
ENDING BALANCE 19,049.84 8,157.79 892.05 0.00
PERIOD: 04 /01/2002 To 04/3012002
Total Principal Interest Expenses
BEGINNING BALANCE 19,049.84 18,157.79 1892.05 10.00
I Total Principal Interest' lExpenses 1
ENDING BALANCE 19,183.73 18,157.79 1,025.94 10.00
PERIOD: 05 /01/2002 To 05/31/2002
jTotal Principal IInterest lExpenses
BEGINNING BALANCE 19,183.73 8,157.79 11,025.94 10.00
Total Principal Interest Expenses
ENDING BALANCE 19,324.13 18,157.79 11,166.34 0.00
PERIOD: 06 /01/2002 To 06/30/2002 1
ITotal Principal ,Interest Expenses
BEGINNING BALANCE 19,324.13 18,157.79 1,166.34 0.00
I Total Principal Interest Expenses 1
ENDING BALANCE
9,462.07 18,157.79
PERIOD: 07101/2002 To 07/31/2002
Total Principal
BEGINNING BALANCE 9,462.07 ? 8,157.79
Total Principal
ENDING BALANCE 19,606.73 18,157.79
PERIOD: 08/01/2002 To 08/31/2002
,,Total Principal'
BEGINNING BALANCE 19,606.73 18,157.79
1
Expenses
1 0.00
Total Principal Interest
ENDING BALANCE 19,753.59 18,157.79 11,595.80
PERIOD: 09/01/2002 To 09/30/2002
w. Total Principal Interest
BEGINNING BALANCE 19,753.59 18,157.79 11,595.80
ENDING BALANCE
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
Expenses
10.00
Expenses
10.00
ITotal Principal _ Interest lExpenses
19,897.89 18,157.79 11,740.10 10.00
PERIOD: 10/01/2002 To 10/31/2002
Total Principal Interest Expenses
19,897.89 1 8,157.79 11, 740.10 10,00
Total Principal
110,049.21 1 8,157.79
PERIOD: 11/01/2002 To 11/30/2002
[Total Principal
110,049.21 18,157.79
Interest Expenses
11,891.42 10.00
Interest Expenses
1,891.42 10.00
ITotal Principal
1 10,197.88 8,157.79
PERIOD: 12/01/2002 To 12/31/2002
Total Principal
110,197.88 8,157.79
1,304.28 ( 0.00
Interest Expenses
1,304.28 0.00
Interest
1 1,448.94
Expenses
10.00
Interest
1 1,448.94
lInterest- lExpenses
1 2,040.09 10.00
Interest Expenses
1 2,040.09 10.00
(Total (Principal (Interest (Expenses 1
ENDING BALANCE 110,353.78 18,157.79 12,195.99 10.00
PERIOD: 01101/2003 To 01/31/2003 1
'Total Principal II Interest Expenses
BEGINNING BALANCE 110,353.78 8,157.79 2,195.99 10.00
Total Principal Interest Expenses 1
ENDING BALANCE 110,512:07 18,157.79 12,354.28 10.00
PERIOD: 02/0112003 To 02/28/2003 1
Total Principal Interest Expenses
BEGINNING BALANCE 110,512A7 18,157,79 12,354.28 10.00
Total (Principal Interest Expenses 1
ENDING BALANCE 110,657.22 18,157,79 12,499.43 10.00
L PERIOD: 03/01/2003 To 03/3112003
Total (Principal Interest Expenses
BEGINNING BALANCE 110,657.22 18,157.79 12,499.43 10.00
Total - Principal Interest Expenses
ENDING BALANCE 110,820.14 8,157.79 1'2,662.35 10.00
PERIOD: 04/01/2003 To 04/30/2003 1
Total (Principal Interest Expenses
BEGINNING BALANCE l10,820.14 1$,157.79 12,662.35 10.00`
Total Principal Interest (Expenses
ENDING BALANCE 110,980.22 18,157.79 12,822.43 10,00
PERIOD: 05 /01/2003 To 05/31/2003
Total (Principal Interest Expenses
BEGINNING BALANCE 110,980.22 18,157.79 12,822.43 10.00
Total Principal Interest Expenses
ENDING BALANCE 111,148.08 18,157.79 12,990.29 0.00
PERIOD: 06 /01/2003 To 06/30/2003 1
Total Principal Interest !Expenses 1
BEGINNING BALANCE 111,148.08 8,157.79 12,990.29 0.00
Total Principal - Interest Expenses 1
ENDING BALANCE
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
1 11,313.01 1 8,157.79 ( 3,155.22 0.00
PERIOD: 07/01/2003 To 07/31/2003
Total (Principal Interest Expenses
11,313.01 18,157.79 13,155.22 1 0.00
Total Principal Interest Expenses
1 11,485.96 18,157.79 3,328.17 1 0.00
PERIOD: 08/01/2003 To 08/31/2003
Total Principal Interest Expenses
1 11,485.96 18,157.79 1 3,328.17 10.00
Total Principal
ENDING BALANCE 111,661.56 18,157.79
PERIOD: 09/01/2003 To 09/30/2003
(Total Principal
BEGINNING BALANCE 111,661.56 18,157.79
Interest Expenses
13,503.77 10.00
Interest [Expenses
1 3,503.77 10.00
(Total Principal Interest Expenses
ENDING BALANCE 111,834.08 8,157.79 3,676.29 10.00u
PERIOD: 10/01/2003 To 10/31/2003 1
Total Principal Interest Expenses
BEGINNING BALANCE 111,834.08 18,157.79 13,676.29 10.00
'Total Principal (Interest Expenses
ENDING BALANCE 112,015.00 18,157.79 13,857.21 10.00
PERIOD: 11/01/2003 To 11/30/2003
Total Principal ,Interest Expenses
BEGINNING BALANCE 112,015.00 18,157.79 13,857.21 10.00
Total [Principal (Interest Expenses
ENDING BALANCE 112,192.76 8,157.79 14,034.97 0.00
PERIOD: 12/01/2003 To 12/31/2003
1 Total Principal Interest `Expenses
BEGINNING BALANCE 1-12,192.76 18,157.79 14,034.97 10.00
(Total Principal lInterest Expenses
ENDING BALANCE 12,379.16 18,157.79 14,221.37 10.00
PERIOD: 01/01/2004 To 01/31/2004 1
Total Principal Interest Expenses
BEGINNING BALANCE 112,379.16 18,157.79 14,221.37 10.00
Total Principal Interest Expenses
ENDING BALANCE 1"12,568.40 18,157.79 14,410;61 10.00
PERIOD: 02/01/2004 To 0,2/29/2004
Votal Principal Interest Expenses
BEGINNING BALANCE 112,568.40 18,157.79 14,410.61 10.00
I Total (Principal Interest Expenses
ENDING BALANCE 112,748.15 _ 18,157.79 14,590.36 10.00
PERIOD: 03/01/2004 To 03/3112004 1
Total Principal Interest Expenses 1
BEGINNING BALANCE 1„12,748.15 18,157.79 4,590.36 10.00
Total Principal Interest ' Expenses
ENDING BALANCE 112,943.04 18,157.79 14,785.25 10.00
PERIOD: 04/01/2004 To 04/30/2004
Total Principal Interest Expenses
BEGINNING BALANCE (12,943.04 18,157.79 14,785.25 10.00:
Total Principal Interest Expenses
ENDING BALANCE 13,134.52 18,157.79 4,976.73 0.00
PERIOD: 05/01/2004 To 05/31/2004
Total (Principal
(Interest
Expenses
BEGINNING BALANCE 1 13,134.52 18,157.79 14,976.73 10.00
(Total Principal IInterest lExpenses
ENDING BALANCE 113,335.32 18,157.79 15,177.53 10.00
PERIOD: 06/01/2004 To 06/30/2004
Total Principal Interest Expenses
BEGINNING BALANCE 113,335.32 18,157.79 5,177.53 10.00
I Total Principal Interest Expenses
ENDING BALANCE 113,532.61 18,157.79
PERIOD: 07/01/2004 To 07/31/2004
Total Principal
BEGINNING BALANCE 113,532.61 18,157.79
ENDING BALANCE
a
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
ENDING BALANCE
F1
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
15,374.82 X10.00
Interest Expenses
5,374.82 0.00
Total Principal Interest (Expenses
13,739.49 18,157.79 15,581.70 0.00
PERIOD: 08/01/2004-To_ 08131/2004
ITotalPrincipal Interest, Expenses
1 13,739.49 1 8,157.79 15,581.70 1 0.00
ITotal Principal Interest Expenses
1 13,949.54 18,157.79 1 5,791.75 1 0.00=
PERIOD: 09/01/2004 To 09/30/2004
Total Principal Interest Expenses
113,949.54 18,157.79 5,791.75 10.00
ITotal Principal
114,155.91 18,157.79
PERIOD: 10/01/2004 To 10/31/2004
ITotal e Principal
114,155.91 18,157.79
,Interest l Expenses
1 5,998.12 10.00
lInterest lExpenses
15,998-12 10.00
Total Principal
114,372.33 18,157.79
PERIOD- 11/01/2004 To 11/30/2004
ITotal [Principal
114,372.33 18,157.79
lInterest` IExpenses
16,214.54 10.00
`Interest Expenses
6,214.54 0.00
ITotal (Principal, lInterest Expenses 1
114,584.96 18,157.79 6,427.17 0.00
PERIOD: 12/01/2004 To 12/31/2004
Total Principal Interest Expenses
1.;14,584.96 1 8,157.79 6,427.17 0.00
(TotalPrincipal Interest lExpenses
ENDING BALANCE 114,807.93 18,157.79
PERIOD: 01/01/2005 To 01/31/2005
Total l Principal
BEGINNING BALANCE 114,807.93 18,157.79
.Total Principal
ENDING BALANCE ( 15,034.31 8,157.79
PERIOD: 02/01/2005 To 02/28/2005
Total Principal
BEGINNING BALANCE 115,034.31 18,157.79
ENDING BALANCE
T,
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
6,650.14 1 0.00
(,Interest ''Expenses
16,650.14 0.00
Interest Expenses
1 6,876.52 1 0.00
I Interest Expenses
1 6,876.52 1 0.00
ITotal Principal Interest Expenses
115,241.90 18,157.79 17,084.11 1 0.00
PERIOD: 03/01/2005 To 03/31/2005
ITotal Principal lInterest Expenses
1 15,241.90 1 8,157.79 7,084.11 1 0.00
ITotal Principal
1 15,474.92 18,157.79
PERIOD: 04/01/2005 To 04/30/2005
Total Principal
115,474.92 1 8,157.79
Interest Expenses
7,317.13 10.00
lInterest lExpenses
7,317.13 1 0,00
Transactions
lA'mount Transaction Date Type,
100.00 04/15/2005 Payment Without Plan
Total (Principal interest
ENDING BALANCE 115,603.07 18,157.79 17,445.28
PERIOD: 05/01/2005 To 05131/2005
(Total Principal Interest
BEGINNING BALANCE ( 15,503.07 1 8,157.79 17,445.28
lExpenses
10.00
Expenses
0.00
Transactions
Amount Transaction Date Type
100.00 05/1512005 Payment Without Plan
ENDING BALANCE
BEGINNING BALANCE
ITotal Principal
115,740,77 18,157.79
PERIOD-06/01/2005 To 06/30/2005
ITotal Principal
1 15,740.77 18,157.79
Transactions
Amount Transaction Date ITYpe
100.00 06/15/2005 Payment Without Plan
(Total (Principal
ENDING BALANCE 115,872.86 18,157.79
r PERIOD: 07/01/2005 To 07/31/2005
(Total Principal
BEGINNING BALANCE 115,872.86 18,157.79
Transactions
Amount Transaction Date Type
100.00 07/15/2005 Payment Without Plan
Total' (Principal
ENDING BALANCE 116,014.68 18,157.79
PERIOD: 08/01/2005 To 08/31/2005
Total Principal
BEGINNING BALANCE 116,014.68 18,157.79
f?
Transactions
Amount Transaction Date Type
100.00 08/15/2005 l Payment Without Pian
Total I Principal
ENDING BALANCE 116,158.67 18,157.79
PERIOD: 09/01/2005 To 09/30/2005
Total Principal
BEGINNING BALANCE 116,158.67 18,157.79
interest Expenses'
17,582.98 0.00
I
Interest Expenses
7,582.98 10.00
`interest Expenses
1 7,715.07 10.00
Interest Expenses
7,715.07 0.00
Interest Expenses
7,856.89 10.00
Interest Expenses
1 7,856.89 10.00
(Interest Expenses
8,000.88 10.00
Interest Expenses
18,000.88 0.00
Transactions
`.Amount
100.00
ITransaction Date Type
109/15/2005 I Payment Without Pian
ITotal Principal
1 16,296.94 18,157.79
PERIOD: 10/01/2005 To 10/31/2005
Total I Principal
ENDING BALANCE
BEGINNING BALANCE
Transactions
Amount
100.00
ENDING BALANCE
BEGINNING BALANCE
1 16,296.94 18,157.79
Transaction Date Type
10/15/2005 I Payment Without Plan
ITotal Principal
16,445.24 8,157.79
PERIOD: 11/01/2005 To 11/30/2005
ITotal Principal
116,445.24 8,157.79
!Interest Expenses
18,139.15 10.00
(Interest !Expenses
1 8,139.15 10.00
Interest !Expenses
8,287.45 10.00
Interest iExpenses
? 8,287.45 1 0.00
Transactions
(Amount (Transaction Date (Type(
1 100.00 111/15/2005 1 Payment Without Pian
ENDING BALANCE
BEGINNING BALANCE
Transactions
Amount
100.00
ITotal Principal
1 16,587.75 1 8,157.79
PERIOD: 12/01/2005 To 12/31/2005
Natal (Principal
116,587.75 8,157.79
Transaction Date
112/15/2005
(Type
I Payment Without Pian
Total Principal
ENDING BALANCE 116,740.50 18,1_57.79
Unter'est !Expenses
8,429.96 0.00
Unterest
8,429.96
Expenses
0.00
Interest !Expenses
8,58171 10.00
PERIOD,: 01/01/2006 To 01/31/2006
Total Principal
BEGINNING BALANCE 116,740.50 18,157.79
Transactions
Amount
100.00
(Transaction Date Type
101/15/2006 Payment Without Plan
ENDING BALANCE
BEGINNING BALANCE
Transactions
Amount
100.00
ENDING BALANCE
BEGINNING BALANCE
Total Principal
16,895.59 18,157.79
PERIOD: 02/01/2006 To 02/28/2006
Total (Principal
116,895.59 18,157.79
(Transaction Date
102/15/2006
Interest Expenses
8,582.71 1 0.00
Interest !Expenses
18,737.80 10.00
Interest Expenses
18,737.80 10.00
(Type
Payment Without Ran
ITotal Principal
117,028.19 18,157.79
PERIOD: 03/01/2006 To 03/31/2006
Total (Principal
117,028.19 18,157.79
Interest (Expenses
8,870.40 0.00
Interest 'Expenses
18,870.40 0.00
Transactions
jj
Amount Transaction 'Date ,Type
l100.00 03/15/2006 Payment Without Plan
ENDING BALANCE
is
BEGINNING BALANCE
ENDING BALANCE
Votal Principal
117,187.68 8,157.79
PERIOD: 04/01/2006 To 04/30/2006
Total !Principal
117,187.68 8,157.79
ITotal Principal
117,441.96 8,157.79
Interest !Expenses
1 9,029.89 1 0.00
'Interest Expenses
9,029.89 10.00
!Interest Expenses
19,284.17 10.00
PERIOD: 05/01/2006 To 05131/2006
Potal Principal
BEGINNING BALANCE 117,441.96 8,157.79
'Interest
1 9,284.17
ITotal Principal 1lInterest
ENDING BALANCE 117,708.61 18,157.79 19,550.82
PERIOD: 06/01/2006 To 06/30/2006
Total Principal Interest
BEGINNING BALANCE 117,708.61; 18,157.79 19,550.82
ENDING BALANCE
BEGINNING BALANCE
ENDING BALANCE
BEGINNING BALANCE
ENDING BALANCE
^a
BEGINNING BALANCE
ENDING BALANCE
r
BEGINNING BALANCE
ENDING BALANCE
[r Expenses
0.00
Expenses
0.00
Expenses
1 0,00
ITotal Principal Interest [Expenses
1 17,970.60 18,157.79 19,812.81 10.00
PERIOD: 07/01/2006 To 07/31/2006
Total Principal Interest Expenses
1 17,970.60 - 18,157.79 19,812.81 10.00
ITotal Principal
118,245.33 ? 8,157.79
PERIOD: 08/01/2006 To 08/31/200E
ITotal Principal
Interest lExpenses
1 10,087.54 10.00
118,245.33 18,157.79
I Total R Principal
118,524.26 8,157.79
PERIOD: 09/01/2006'To 09/3012006
Total (Principal
1 18,524.26 18,157.79
(Total ' Principal
118,798.31 8,157.79
PERIOD: 10/01/2006 To 10/31/2006
Total (Principal
118,798.31 18,157.79
Total Principal
1 19,085.70 8,157.79
Interest lExpen'ses
110,087.54 10.00
Interest lExpenses
10,366.47 0.00
Interest IExpenses
10,366.47 -, 1 0.00
1Interest Expenses
10,640.52 10.00
'Interest Expenses
10,640.52 10.00
IInterest lExpenses
10,927.91 1 0.00
PERIOD: 11/01/2006 To 11/30/2006
(Total Principal (,!Interest Expenses
BEGINNING BALANCE119,085.70 18,157.79 10,927.91 10.00
ITotal Principal [Interest Expenses
s>
ENDING BALANCE 119,368.06 18,157.79 111,210.27 10.00
Helene B. Raush, Esq.
Bar No: 60140
Stewart & Associates, P.C.
P.O. Box 2629
Suwanee, GA 30024
(866) 990-9968 phone
(678) 684-4975 fax
CREDIGY RECEIVABLES INC., )
Plaintiff, )
VS. )
REBECCA P ASH, )
Defendant. )
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
TRIAL DIVISION
Civil Action No.:
CERTIFICATE OF SERVICE OF DISCOVERY
This is to certify that a copy of the PLAINTIFF'S FIRST REQUEST FOR
ADMISSIONS TO DEFENDANT was attached to the Complaint herein. The Notice to
Defend, Complaint, and Verification, along with the Plaintiff's First Request for Admissions to
Defendant, have been submitted to the court for filing and will be forwarded for service of
process to the Defendant at the following adress:
746 ERFORD RD, CAMP HILL, PA 17011-1125
This the 2 8?6 day of ?)P t _ , 200(-
Respectfully Submitted,
/" '^ / _ ,/j -- 4A
Helene B. Raush, Esq.
Bar No: 60140
Stewart & Associates, P.C.
P.O. Box 2629
Suwanee, GA 30024
(866) 990-9968 phone
(678) 684-4975 fax
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-00049 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CREDIGY RECEIVABLES INC
VS
ASH REBECCA P
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
ASH REBECCA P the
DEFENDANT , at 1250:00 HOURS, on the 5th day of January-, 2007
at 746 ERFORD ROAD
CAMP HILL, PA 17011-1125
REBECCA ASH
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
of
So Answers:
18.00
13.20 .00
10.00 R. Thomas Kline
.00
41.20,/ 01/08/2007
STEWART & ASSOCIATES
Y: ,e?
day De ty eri
A.D.
IN THE COMMON PLEAS COURT IN AND
FOR CUMBERLAND COUNTY, PENNSYLVANIA
CREDIGY RECEIVABLES INC., CASE NO. 2007-00049
COURT TERM: 2007-01
Plaintiff,
vs.
REBECCA P ASH,
Defendant.
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
COMES NOW Plaintiff, CREDIGY RECEIVABLES INC., and herewith
discontinues the above styled action against Defendant, REBECCA P ASH, without
prejudice and herein requests the Prothonotary to mark said case as discontinued upon the
record.
On this 7 4 day of - , 2007
4?W;e 444Z
Helene B. Raush, Esquire
PA Bar No: 60140
Attorney for Plaintiff
Helene B. Raush, Esquire
Attorney for Plaintiff
STEWART & AssoCI m, P.C.
P.O. Box 2629
Suwanee, GA 30024
866) 990-9968
678) 684-4975 (fax)
1,
IN THE COMMON PLEAS COURT IN AND
FOR CUMBERLAND COUNTY, PENNSYLVANIA
CREDIGY RECEIVABLES INC., CASE NO. 2007-00049
COURT TERM: 2007-01
Plaintiff,
VS.
REBECCA P ASH,
Defendant.
CERTIFICATE OF NON-SERVICE
I certify that service of the Praecipe to Discontinue Without Prejudice upon the
defendant was not possible. Service of process was not perfected upon this defendant and
his/her location is unknown at this time.
On this t?b day of 20Z?
Helene B. Raush, Esq.
PA Bar No: 60140
Attorney for Plaintiff
Helene B. Raush, Esquire
ff
Attorney for Plainti
STEWART & ASSOCIATES, P.C.
P.O. Box 2629
Suwanee, GA 30024
(866) 990-9968
(678) 684-4975 (fax)
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