Complaint Limited Up to 10KCal. Super. - 6th Dist.April 19, 2021DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF PLD-C-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar mmber, and address): FLINT C ZIDE, SBN 160369/SARKIS S KARAYAN, SBN 316926 LAW OFFICE OF HARRIS & ZIDE 1445 HUNTINGTON DRIVE, SUITE 300 SOUTH PASADENA CA 91030 TELEPHONE No: 525-799-3444 FAX NO. (0900M): 626-799-8419 E-MAIL ADDRESS (Optional).- ATrORhEY FOR (Name): PLA] NTI FF SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SANTA CLARA Electronically flled smeenooness: 191 NORTH 151' STREET by Superlor Court of CA, mum; monass: County of Santa Clara, crrv mozw cons: 53" 1°58 CA 95113 on 4/1 9/2021 2:04 PM amen NAME: 5A” JOSE COURTHOUSE Reviewed By:AshIey Mackenzie PLAINTIFF: JEFFERSON CAPITAL SYSTEMS, LLC Case #21 CV381 31 4 Env #6268551 FOR COURTUE ONLY DEFENDANT: JANET L CORNELL E DOES 1 To 5. INCLUSIVE CONTRACTE compLAmT E AMENDED COMPLAINT (Number): E CRoss_COMpLAmT E AMENDED CRoss.compLAINT (Number): Ju risdiction (check all that apply): _ ACTION Is A LIMITED CIVIL CASE CASE ”UMBER Amount demanded X_ does not exceed $10,000- exceeds $1 0,000 but does not exceed $25,000 jg ACTION Is AN UNLIMITED CIVIL CASE (exceeds $25,000) i: ACTION IS RECLASSIFIED by this amended complaint or cross-complaint 21 CV381 31 4 Efrem limited to unlimited Efrem unlimited to limited 1. Plaintiff“ (name or names): JEFFERSON CAPITAL SYSTEMS, LLC alleges causes of action against defendant" (name or names): JAN ET L CORNELL DOES 1 T0 5, INCLUSIVE 2. This pleading, including attachments and exhibits, consists of the following number of pages: 3. a. Each plaintiff named above is a competent adult except plaintiff (name): JEFFERSON CAPITAL SYSTEMS, LLC (1) Ea corporation qualified to do business in California (2) man unincorporated entity (describe): (3) -other (specify): LIMITED LIABILITY COMPANY b.E Plaintiff (name).- a. Ehas complied with the fictitious business name laws and is doing business under the fictitious name (specify): b4E has complied with all licensing requirements as a licensed (specify): c,E Information about additional plaintiffs who are not competent adults is shown in Attachment 30. 4. a. Each defendant named above is a natural personE except defendant (name): E except defendant (name): (1)E a business organization, form unknown (1)E a business organization, form unknown (2)D a corporation (2)E a corporation (3)E an unincorporated entity (describe): (3)E an unincorporated entity (describe): (4)E a public entity (describe): (4)E a public entity (describe): (5) mother (specify): (5)E other (specify): " If this form Is used as a cross-complalnt. flainflff means crass-oomplainant and defendant meanscmss-defendant. Paga 1 of 2 Fmmmxfiégmfl” TA048070 COMPLAINT-Conh'act Code of Clvu Procedure, § 425.12 PLD-tmm [Rem January 1.2007] DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF PLD-C-001 SHORT THE: JEFFERSON CAPITAL SYSTEMS, LLc Vs. JANET L CORNELL CASE NUMBER: 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. (1) D Doe defendants (specify Doe numbers): were the agents or employees of the named defendants and acted within the scope of that agency or employment. (2)D Doe defendants (specify Doe numbers): are persons whose capacities are unknown to plaintiff. c. D Information about additional defendants who are not natural persons is contained in Attachment 4c. d, E Defendants who are joined under Code of Civil Procedure section 382 are (names): 5. D Plaintiff is required to comply with a claims statute, and a. D has complied with applicable claims statutes, or b. D is excused from complying because (specify): 6. D This action is subject t0 D Civil Code section 1812.10 D Civil Code section 2984.4. 7. This court is the proper court becauseD a defendant entered into the contract here.D a defendant lived here when the contract was entered into. a defendant lives here now.D the contract was to be performed here.D a defendant is a corporation or unincorporated association and its principal place of business is here.D real property that is the subject of this action is located here.E other (Specify): CCP 395(3) 20950519?!» 8. The following causmc of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): D Breach of Contract m Common Counts D Other (specify): 9. E Other anegafiuns; Plaintiff i5 a debt buyer and the sole uwner/assignee of an agreement entered into by defendant(s) on a credit card account ending in 9369 with Plaintiff’s predecessor WEBBANK Plaintiff having taken said assignment for value. This account was purchased by plaintiff after 1f1/14. 10. Plaintiff prays for judgment for costs of suit; for sum relief as is fair, just, and equitable; and for a. damages of: $ $1,281.32 b. D interest on the damages (1)D according to proof (2)D at the rate of (specifil): percent per year from (date): c. D attorney's fees (1)D of: $ (2)E according to proof. d. m other (special): SUCH OTHER RELIEF AS THE COURT DEEMS PROPER. 11. D The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: 04/16/2021 DocuSigned by. U FLINT C. ZIDE D SARKIS S. KARAYAN ’EMIS S WMM (TYPE 0R PRINT NAME) U 'WWESTIEENEXWRE 0F PLAINTIFF 0R ATrORN EY) (Ifyou wish to verifl/ this pleading, afi'x a verification.) PLDWM [Rev- January 1.20071 COMPLAINT-Contract Paaezofz DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF PLD-c-oo1(2) SHORT TITLE: JEFFERSON CAPITAL SYSTEMS, LLC Vs. JANEI' L CORNELL CASE NUMBER: FIRST (number) CAUSE OF ACTION-Common Counts ATTACHMENTTO Complaint D Cross-Complaint (Use a separate cause of action fonn for each cause ofacfion.) 00.1, Plaintiff (name); JEFFERSON CAPITAL SYSTEMS, LLC alleges that defendant (name): JANET l. C0 RNELL became indebted to plaintiff D othermame): a. within the last four years (1) on an open book account for money due. (2) because an account was stated in writing by and between plaintiff and defendant in which it was ag reed that defendant was indebted to plaintiff. b. m within the last E two years four years (1) for money had and received by defendant for the use and benefit of plaintiff. (2) D for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff.D the sum of $D the reasonable value. (3) D for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiffD the sum of $D the reasonable value. (4) m for money lent by plaintiff to defendant at defendant's request. (5) for money paid, laid out, and expended to or for defendant at defendant's special instance and request. (6) D other (specify): CC-2. $ , which is the reasonable value, is due and unpaid despite plaintiff's demand, plus prejudgment interest D according to proof D at the rate of percent per year from (date): CC-3. D Plaintiff is entitled to attorney fees by an agreement or a statute CC-4. Other: D of$D according to proof. $1,281.32, which i5 the fixed and agreed amount, is due and unpaid despite plaintiff's demand. Plaintiff is the sole owner and current assignee ofthis account, whose account number at time of charge off ended in 9369, and was originally owned by WEBBANK, 215 SOUTH STATE ST STE 800 , Salt Lake City, UT 34111 who was the creditor at time of charge off. $1,351.31 was the balance at time of charge off, as shown by Attachment 1. Defendant made a payment prior to charge off on September 15, 2017, as shown by Attachment 2. The last payment was made on this account on May 1, 2018, as shown by Attachment 3. The debtor's name and address appeared in the original creditor's records prior to the sale of the debt or as of 12/31/13, as shown in Attachment 3. The names and addresses of all entities who have purchased the debt after charge off are as follows on Attachment 3. Plaintiff has complied with Civil Code Section 1788.52. Page Pagc1 of 1 FormApprmed for Optional Use CAUSE OF ACTION_c°mm°n counts Code of Clvll Procedure, § 425.12 Judicial Council of Callfomla PLD-C-001(2) [Rev. January 1. 2009] www. courflnfona‘gov DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81BGD963FF ATTACHM ENT ”1” DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF FiNGERHUT . Advantage I Previous Balance 1,322.50 Payments & Credits 0.00 Purchases & Debits 0.00 Fees Charged 0.00 Interest Charged 28.81 New Balance 1,351 .31 Credit Limit o Available Credit 0 Statement Closing Date 03/19/18 Days in Cycle 28 Past Due Amount 409.94 Minimum Payment Due 479.93 Interest Charge Calculation Type of Annual Percentage Balance Subject Interest Balance Rate (APR) to Interest Rate Charge Non Deferred 26.15%(v) 1,322.50 28.81 (v) APR will vary with the market, based on the Prime Rate. Fees Date Order Number TOTAL FEES FOR THIS PERIOD Interest Charged 08/1 9/1 8 TOTAL INTEREST THIS PERIOD TOTAL FEES YTD 2018 TOTAL INTEREST YTD 2018 PamW-lnfdrmaflon New Balance 1,351 .31 Minimum Payment Due 479.93 Mail Payment By 04/08/18 Payment Due Date 04/1 5/18 Late Payment Warning: If we do not receive your minimum payment by the Payment Due Date listed above, you may have to pay a late fee of up to $38.00. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it wi|| take you longer to pay off your balance. For example: If you make no additional charges using this card and each month you pay: Onlythe minimum payment If you would like information about credit counseling services call 1-888-364-2268. To avoid additional interest charges, pay the New Balance by the Payment Due Date. You will pay off the And you will end up balance shown on this paying an estimated total statement in about: of: 5 years $1 ,732 Description Amount 0.00 INTEREST CHARGE 28.81 28.81 0.00 84.61 You Are ENROLLED in SAFELINE, an optional program, which can be canceled at any time. For any questions, please visit safeline.fingerhut.com or call 1-855-582-21 28. NOTICE: See Reverse Side for Important Information Inquiries Regarding Your Fingerhut Advantage Credit Account issued by WebBank: English: 1-800-208-2500 En Espafiol: 1-800-556-3208 FiNcERHUI . Advantage Account Number MAIL PAYMENT BY MINIMUM DUE Makepuymhnté dhlina atm.fingarhut.comMyAmunt 0r tear off and return with your payment by mail. Make your check payable to Fingerhm. New Balance Amount Enclosed XXXX-XXXX-XXXX-9369W” 04/08/1 8 $479.93 $1,351.31 - JANET L CORNELL 1394 MOONLIGHT CIR MILPITAs CA 95035-6224 Make your check payable to Fingerhut and mail to: PO BOX 166 NEWARK, NJ 071 01 -01 66 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF You paymenl will be credited Io your account on the same day we receive a'l if the bollnm porljon of mis slalemenl and your check are received by us on a processing day by 5:00 prn Eastern Time in Ihe enclosed envempe at our processing oenler. Payments received afler 5:00 pm Easlern Time wi1l be crediled on Ihe nexl processing day. Piease allow al leasl seven (7] days for postal delivery. Paymenls received al any olher location in anolher form or with umer dowmems may nol be credited Ihe same day we receive Ihe payment. Our processing days are Monday through Sunday. excluding holidays for paymenls received by mai. Paymenls received on holidays will be credited as of lhe previous processing day. When you send us a meek as a paymenl. you aulhorize us lo use information from your check to make a one-Iime eleclranic fund transfer from your depusil account. or to process lhe payment as a check lransacfion. When we use informalion from your check ta make an elemronic fund transfer. funds may be wilhdrawn from your deposil account as soon as lhe same day we waive payment. and you will not receive your check back from your financial institution. If your check i5 returned Io us due lo non-sutficienl funds we may also re-deposit it through a ona-lime electronic fund Hansfer. You may also make a paymenl at anytime on ywr Fingemut Advantage Account at fingerhutmmrMoncount 0r via an aulomaled phone payment at 18w 208-2500. Online and amomaled phone paymenls will be posled as of the same day if made before 11:00 pm Cenh'al Time. If your smtement shows a credit balance. you may requesl a refund ol Ihe credil by conlacljng Fingerhui Credit Setvices. at me address shown below. You may pay the entire balance on your account al anylirne wiihoul inwring any additional charges for prepayment. PAYMENTS Make chads payable to Fingemul and mail lo: Fingerhm CreditAcoounl Services. P.0. Box 165. Newam, NJ 07101-0166 Hesse wn'le your Firrgemul Manage Acouunl mmber on you check. Do nol send correspondence Io this address. Mail your paymenl in file endosed envelope wi’m me payment coupon at [he bottom of your statement. WHAT T0 D0 IF YOU THINK YOU FIND A MISTAKE 0N YOUR STATEMENT If you think there is an error on your slatemenl, wrile us al: Fingemut Credit Acouunl Services. PD. Box 1250. Sainl Cloud MN 55395-1250. invesljgate, me same rues apply la H19 dispuled amount as discussed abnve. Aflar we finish out invesfigafion. we will lall 5m our decision. Al lhat poinL if we think you owe an amount and you do nut pay we may report you as delinquent CREDIT BUREAU DISPUTES If you believe we inaccuralely reporled credit history infumafian about you or yuurAccwnl to a oredil reporting agency. write Io us at: Credit Bureau Reporting Services. 6250 Ridgewood Road‘ Sainl Cioud MN 56303. Please provide 1er Fingerhui Advantage Credt Account number a1ong with a copy of your oredil bureau report reflecting the information that you believe is inaccurate. HOW WE CALCULATE INTEREST CHARGES Ta calculate me inlerest charge payable each mamh. we mulfiply the average daily balance times lhe monlhly pen‘odic rale. Your monlhly periodic rale may vary each biliing cycle. The monlhly pen'odic rale is determined by dividing Ihe APR by 12. Your Mccunt is subiect to a minimum inlerest charge of $1.00. Average Dai1y Balance: We figure lhe inleresl oha'ge on your Account by applying me monthly pen'odic rale Io the “average daily balance” of you Account. indud'ng current hansacfions. To gel Ihe “average daily balance‘ we lake the beginning balance of your Amounl. each day‘ add any new purchases. charges and olhet fees, and sublracl any payments or credils. This gives us the daily balance. Then. we add up all Ihe daily balances for [hat bnling cycle and divide the total by the number of days in me billing cyde. This gives us the "average daily Mame”. Interesl charges begin lo accrue on each purchase on the dale of the purchase. However. if you paid the new balance on your previous Stalement by Ihe paymenl due date shown an the stalement. then: (1 } if you pay lhe new balance on your current billing statement by the paymenl due date shown. we impose no interesl charges on purchases during the current billing cycle. and (2) ‘rf you make a payment by lhe payment due dale shown on your current bdlling statement that is less than the new balance. we will credit Ihal payment as ol lhe first day in your currenl billing cycle. In addiljon, if your Stalement reflecled a new balance and you did not pay Ihat new balance 1n lull by Ihe payment due dale on thal previous slalerrenl, men we will nol impose inlerest charges on any purchases during the currenl billing cyds if you pay Ihe balance shown on your current Slalemenl by the paymenl due dale refiecied on Ihat mrrent statement. DEFERRAL PERIODS In your Ieller. give us the [allowing infotrnation: - Acomnl Information: Your name and WebBankfFirgemulAdvanlage Credit Account Number. - Dular Amount: The dollar amwnl of Ihe suspecled error. - Descripfiun of Problem: If you Ihink there is an error un your bill, describe whal you believe is wrong and why you believe it is a mistake. Yuu mus! mntaci us wilhin 60 days afier Ihe error appeared on your slatemant. You must notify us of any polenfial errors in wriling. You may cail us. bul 'rf yw do we are not requ‘red lo investigate any polenl'al enors and you may have In pay Ihe amount in quesljon. an'le we investigale whelher or nol there has been an enor. the tolbwing are lrue: - We mnnot lry to oolled me amount in quesh'on, or report you as deiinquem. - The charge in quesfion may remain on your stalement. and we may continue lo charge you interest on thalamount. Bul. if we determine thalwe made a mistake. you will not have to pay lhe ammnl i1 question or any interest or olhe! fees related to Ihat amount. - While you do not have to pay the amount in quesljon. you are responsible for the remainder of your balance. - We can apply any unpaid amounl againsl your credit limit. YOUR RIGHTS IF YOU ARE DISSATISFIED WITH YOUR CREDIT PURCHASES If you use your card lo make a purchase and you are dissatisfied with the goods or services that you receive. you may have Ihe right nolto pay the remaining amounl due on me purchase. To use mis right. all of Ihe lollowing must be true: 1. The purchase must have been made in your home Slate or wiihin 100 miles of your current mailing address. and the purchase price must have been more Ihan $50. (Nola: Nahher of these are messary if your purchase was based on an advefliserrml we mailed lo you, or 'tf we own me company that sold you Ihe goods or services.) 2. You must have used your mrd for Ihe purchase. 3. You must have not yel fully paid for Ihe purchase. If all of [he crieda above are met and you are slill dssau‘sfied wilh Ihs wchase, onnlam us in wriling at: Fingamut Credit Account Services, PD. Box 1250. Saint Cloud MN 56395-1250. WebBank may offer Accounls promotional credit offem. induding deferred payment ofiers. Special rules apply to promoljonal credit uflers. which are described at the lime uf1he aflar. 'The dale. amount and descripljon of each purchase are idenfified an you pefiudic statement for Ihe period when y(m make the mrchasa. o Each periodic slalernenl oonlains a summary of all acfive deferred offers, hduding unpa‘d balanca, any intemsl charges and Ihe dale on which me deferral periods Expire. - We figure inleresl charges each munlh by multiplying Ihe average daily balance of each deferred balance by the monlhly periodic rate. ' We do consider all defen'ed purchases for purposes of determining your available credit. NOTICE 0F ASSIGNMENT: The righl to teceive payment on you Fingerhui Advantage Cmdil Accounl has been assigned by WebBank to Fingemut. MARYLAND RESIDENTS Maryland law requires thal if you send us a wtifhen requesl about the status of var awouni and we do nol answer [hat requesl wilhin 60 days afler we receive iL you are nol raqired to pay a finance charge for thal 60 day period or unlil we answer. QUESTIONS ABOUT YOUR STATEMENT Email us at wslomerseMoe©fingermeoom or cal 1600-2084500 (English) 1-800-5563203 (En Espafial) 64262 ID“? IMPORTANT! Has your address, phone number, or e-mail address changed? If so, please fill in any NEW information in the spaces below and we will update your account. Account I ‘ Phone' I | Namelf'i'li'flfijijr‘lii',|'f"|. 4,| Addressllfili‘Lliiijlrlilili'ilfiil City Ii"'|‘i'|""|l'l‘StateTflapiiiil E-Mail Address Please provide your e-mail address for business transactions. (We will not send promotional material without your permission.) D Check here if you'd like to receive emails about Fingerhut special deals and events. Consent for Use of Telephone Numbers: You authorize WebBankIFingemut. their affiliates. agents. and others calling at their request or on their behalf to contact you at any number (i) you have provided to us (ii) from which you have called us, or (iii) which we obtain and believe we can reach you at. We may contact you in any way. such as calling, texting, using an automated dialer or using pre-recorded messages We may oontact you on a mobile, wireless, 0r similar device, even if you are charged for it by your provider. DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81BGD963FF ATTACHM ENT ”2” DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF FiNcERHUT . Advantage Previous Balance 1,096.86 -. - . . Payments & Credits 70.00 Paym’m '“hmat'” Purchases & Debits 0.00 New Balance 1,06278 Fees Charged 12-50 Minimum Payment Due 59.99 IntereSt Charged 23-42 Mail Payment By 10/08/17 New Balance 1’062-78 Payment Due Date 10/1 5/17 Greg“ Limit I 1'550 Late Payment Warning: If we do not receive your minimum Ava'lable cred't 487 payment by the Payment Due Date listed above, you may have to pay Statement Closing Date 09/19/17 a late fee of up to $38.00. Days m Cyde 31 Minimum Payment Warning: If you make only the minimum Past Due Amount 0.00 payment each period, you will pay more in interest and it wi|| take you Minimum payment Due 5939 longer to pay off your balance. For example: _ If you make no additional You will pay off the And you will end up 'mereSt Charge calcu'atlon charges using this card balance shown on this paying an estimated total and each month you pay: statement in about: of: Type of Annual Percentage Balance Subject Interest Only me minimum 5 years $1 1503 Balance Rate (APR) to Interest Rate Charge payment Non Deferred 25.90%(v) 1 ,085.56 23.42 If you would like information about credit counseling services call 1-888-364-2268. (v) APR wi|| vary with the market, based on the Prime Rate. Transactions Date Order Number 09/1 5/1 7 Fees 09/1 9/1 7 TOTAL FEES FOR THIS PERIOD Interest Charged 09/1 9/1 7 TOTAL INTEREST THIS PERIOD TOTAL FEES YTD 2017 TOTAL INTEREST YTD 2017 To avoid additional interest charges, pay the New Balance by the Payment Due Date. Description Amount PAYMENT - THANK YOU -70.00 SAFELINE PLUS FEE 12.50 12.50 INTEREST CHARGE 23.42 23.42 188.43 236.66 You Are ENROLLED in SAFELINE, an optional program, which can be canceled at any time. For any questions, please visit safeline.fingerhut.com or call 1-855-582-21 28. NOTICE: See Reverse Side for Important Information Inquiries Regarding Your Fingerhut Advantage Credit Account issued by WebBank: English: 1-800-208-2500 En Espafiol: 1-800-556-3208 flake;me onilne at www.fingerhutcomIMyAccount FiNGERHUI . Advantage 0r tear off and return with your payment by mailv Make your check payable to Fingerhut. Account Number MAIL PAYMENT BY MINIMUM DUE New Balance Amount Endosed XXXX-XXXX-XXXX-9369 Customer Number 10/08“ 7 $5999 $1 962.78 Make your check payable to Fingerhut and mail to: PO BOX 166 NEWARK, NJ 071 01 -01 66 JANET L CORNELL 1394 MOONLIGHT CIR MILPITAS CA 95035-6224 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF Your payment will be uedited to your account on the same day we receive it if the bollom portion of this statement and you: check are received by us on a processing day by 5:00 pm Eastern Time in me enclosed envelope at our processing center. Payments received afle: 5:00 pm Eastern Time will be credited on the nexl processing day. Please allow al least seven (7} days fur postal delivery. Payrnenls received at any olhe: location in anomer form or with other documents may nol be orediled me same day we receive me payment. Our processing days are Monday Ihrough Sunday‘ excluding holidays for payments received by mail. Payments received on holidays will be uedited as of me previous processing day. When you send us a check as a payment. you aulhorize us to use information from your check to make a oneJime electronic fund transfer from your deposit account. or to process me paymenl as a check lransaction. When we use information from your check Io make an electronic fund hansfer, funds may be wi1hdrawn fmrn yum deposit account as soon as lhe same day we reoeive pawnent. and you will no! receive your check back from your financial inslitulion. If your check is returned to us due to non-sufficient funds we may also r&depnsil it through a one-Iime electronic fund transfer. You may also make a payment at anytime an your Fingerhut Advantage Account at fingerhutmmu'MyAccount or via an automated phone payment at 1300- 203-2500. Online and automated phone payments will be posted as of the same day if made before 11:00 prn Central Time. If your stalement shows a :md'rl balance, you may request a Iefund of lhe credit by mntanling Fingemul Credit Services, at the address shown below. You may pay the entire balance on your account at any‘lime without incuning any additional merges for ptepaymem. PAYMENTS Make checks payable to F'mgerhul and mail to: Fingerhul Credit Amount Services, PD. Box 166, Newark, NJ 071010166 Please wn'te your Fingerhut Advantage Account number on ywr check. Do nut send correspondence tn this address. Mail your payment in the encbsed envelape with Ihe payment coupon al me bottom of your statement. WHAT TO DO IF YOU THINK YOU FIND A MISTAKE ON YOUR STATEMENT If you think there i5 an error an your statement. write us 3|: Fingerhul Credit Account Sewioes‘ PD. Box 1250. Saint Cloud MN 56395-1250. In your 1elter‘ give us the following informan'un: - Account Infamation: Your name and WebBankIFingerhulAdvanlage Credil Account Number. ' Dalfar Amount: The dollar amount of me suspecmd Error. - Description of Problem: If you mink [here is an error on your bill. describe what you believe is wmng and why you believe it i5 a mistake. You must contact us wilhin 60 days afier the enor appeared on your statement. You must notify us of any potential enors in wriling. You may tall us, bul if you do we are not requiled to iwesligate any polenfial errors and you may have to pay lhe amoum in queslion. While we investigate whether or not [here has been an error, the following are lrue: - We mnnot Iry to coflect Ihe amount in question or report you as delinquent. - The charge in question may remain on your stalemem. and we may continue to charge you interest on that amount. But, ifwe determine thalwe made a mistake, you will n01 have to pay lhe amounl in question or any intetest or o1her fees related to lhat amount ' While you do nnl have to pay the amount in question, you ale responsible for the remainder of your balance. - We can appry any unpaid amount against your credit lim‘rl. YOUR RIGHTS IF YOU ARE DISSATISFIED WITH YOUR CREDIT PURCHASES If you use your card to make a purchase and you are dissatisfied with lhe goods 0r santioes [hat you receive, you may have [he n'ght nol t0 pay the remaining amount due on the purchase. Tn use this n'ght, all of the failowing must he true: 1. The purchase must have been made in yam home State or within 100 miles 01 your current mailing address, and lhe pumhase price must have been more lhan $50. (Note: Neifl'IEI of mesa are necessary if your purchase was based on an advertisement we mailed lo you. or if we own the company thai sold you me goods or services.) 2. You must have used your card for Ihe purchase. 3. You must have nol yet fully paid for the purchase. invesligale, the same mles apply to the disputed amoum as discussed abave. After we finish our investigation. we will tell you our decision, A1 Ihat point. ii we Ihink you owe an amount and you do not pay we may Ieporl you as delinquent. CREDIT BUREAU DISPUTES If you believe we inaccurately reported uedil history infonTIation about you or your Amount to a uedit reporting agency. cail us al 1365-?34-0342 or wriie to us al: Credit Bureau Reporting Services. 6250 Ridgewood Road. Saint Cloud MN 55303. Please provide me Fingerhut Advanlage Credit Account number along wilh a mpy of your credit bureau report reflecting Ihe infomation lhat you believe is inaccuraie. HOW WE CALCULATE INTEREST CHARGES To calculale Ihe inlerest charge payable each month‘ we multiply the average daily balm times the monthly periodic rate and, il applimble, add any defened inlemsl charge [see DEFERRAL PERIODS). Your monthly periodic rate may vsty each billing cycle. The monthly periodic rate is determined by dividing the APR by 12. Your Amount is subject to a minimum intewst charge of $1.00. Average Daily Balance: We figure the intewest charge on your Account by apptying Ihe monthty periodic rate to the “average dai1y balanoe' oi yum Account, including current transactions. TU get Ihe ‘average daily balance' we {aka the beginning balance 0f yew Acocunl. each day. add any new purchases. charges and other fees‘ and subtracl any paymenis or uedits. Purchases subjed to Deferral Periods descfibed below ale excluded from our calculation of the ‘avelage daily balance‘ LInIiI the day foliowing the expiralion of lhe Deferral Peliod. This gives us lhe daily balance. Them we add up all lhe daily balances for thal billing cycle and divide the total by lhe number of days in the billing cyde. This gives us me ”average daily balance”. Interest charges begin to acctue on each purchase on the dale of the purchase. However. ifyou paid the new ba1ance on your previous Statement by the payment due dale shown on fl'le stalement, lhen: (1} ifyou pay lhe new balance on your currenl billing statement by [he paymenl due dale shown, we impose no interest charges on pumhases during the cunenl billing cycle, and (2) ifyou make a payment by the paymenl due date shown on your current billing statement thal is less lhan the new balance. we will credit lhat paymenl as of the first day in your cunent bi1ling cycle. In addition. if your Statement renamed a new balance and you did nol pay Ihat new balance in full by I119 payment due dale Dn that previous statement. then we will not impose interest charges on any purchases during the cunent billing cycle if you pay the bafanoe shown un your current Statement by The payment due date reflected on [hat current statement. DEFERRAL PERIODS Webfiank may offer Accounts plornofional oredil offers. These offers include. but are not 1imited to, deferred interest offers or reduced paymenls wilh deferred interest offers. Special rules apply to these plomofional credit offers. which are desu'ibed at Ihe lime of the offal. -The date. amount and description of each purchase are identified on your periodic statement far the pen'od when you make the purchase. - Each pen'odic statement oonlains a summary of al] acfive deferred offers, including unpaid principal balances. any accrued inlerest charges and [he date which the principal balance (New Balance) of each plan must be paid in lull lo avoid interest charges in oonnecfion wi1h your purchase. - For oflers with deferred inlerest. if you pay me deferred portion on or before the hsl day of me applicable deferred period you pay no intetesl charges in connection with your purchase. Otherwise, we add a defened interml charge to your Amount on fl'le expilalion date. - We figure aca'ued inlerest charges each month by multiplying the average daily balance ufeach defened balance bylhe munlhly pen'udic rate. - We do consider all deferred purd1ases for purpo9es of determining your available Gedii. NOTICE 0F ASSIGNMENT: The right to receive payment on your Fingerhul Advantage Credil Account has been assigned by WebBank to Fingerhui. MARYLAND RESIDENTS Maryland law requires that ifyou send us a written request about the status of your amount and we do n01 answer Ihat [equal wilhin 60 days afier we receive it, you are nnl required ho pay a finance charge for thal 60 day period or untilw answer. QUESTIONS ABOUT YOUR STATEMENT E-rnail us at wstomersewioe®fingerhutoom or cal! 1300-2032500 (English) 1%00-556-3203 {En Espafid) If all of the cn'teria above are met and you are sfill dissafisfied with lhe purchase. Donlacl us i1 wn'ling at: Fingerhut Credii Account Services. P.0. Box 1250. Saint Cloud MN 56395-1250. IMPORTANT! Has your address. phone number. or e-mail address changed? If so, please fill in any NEW information in the spaces below and we will update your account. Account Name .QLQ; J ;L,;;,,l 9L: AddreSS',iviili.iIl City ?ili‘i‘l':ii‘ E-Mail Address Phone>’:"""'| i, , l, filvlf‘j livlrlrl| ilfl Please provide your e-mail address for business transactions. (We will not send promotional material without your permission.) D Check here if you'd like to receive e-mails about Fingerhut special deals and events. Consent for Use of Telephone Numbers: You authorize WebBanleingerhut. their affiliates. agents. and others calling at their request or on their beharf to contact you at any number (i) you have provided to us (ii) from which you have called us, or (iii) which we obtain and believe we can reach you at. we may contact you in any way, such as calling, texting, using an automated dialer or using pre-recorded messages. We may contact you on a mobile, wireless. or similar device. even if you are charged for it by your provider. DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81BGD963FF ATTACHM ENT ”3” DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF STATEMENT OF ACCOUNT ACTIVITY Consumer Information as of 01/26/2021 JANET LEE CORNELL PO BOX 360854 MILPITAS, CA 56224 Debt Description: FINGERHUT DIRECT MRKTING ACCOUNTNUMBER:-9369 DATE ACCOUNT OPENED: 01/16/2015 DATE ACCOUNT CHARGED OFF: 04/16/2018 Post Date 05/12/2015 31.98 05/12/2015 39.99 05/12/2015 329.99 05/13/2015 51.98 05/13/2015 349.98 05/19/2015 4.78 05/19/2015 406.74 05/27/2015 15.99 05/27/2015 58.99 05/28/2015 74.98 06/15/2015 26.00 06/19/2015 6.16 06/19/2015 9.68 06/19/2015 523.56 07/15/2015 64.98 07/19/2015 5.58 07/19/2015 10.63 07/19/2015 474.79 08/14/2015 34.99 08/15/2015 34.99 08/16/2015 34.99 08/19/2015 5.35 08/19/2015 9.73 08/19/2015 454.88 09/15/2015 34.99 09/18/2015 5.11 09/18/2015 9.32 09/19/2015 434.32 10/15/2015 29.99 10/19/2015 4.92 10/19/2015 8.90 10/19/2015 418.15 Transaction Amount- Transaction Description S&H Sony PS3 Gran Turismo 6 / Shipped P53 SOOGB Hardware - Core / Shipped Purchase Purchase DthrFee Statement Balance S & H "Tor022"" Electric Hedge Trimmer / Shipped" Purchase LateCharge DthrFee Interest Statement Balance Payment DthrFee Interest Statement Balance LateCharge Payment LateChargeRvsl DthrFee Interest Statement Balance Payment DthrFee Interest Statement Balance Payment DthrFee Interest Statement Balance *Excerpt of Account Transactions from the Transaction Data File assigned to Jefferson Capital Systems, LLC pursuant to the Bill of Sale dated 5/30/2018 JCAP REFERENCE#- Page 1 of 6Purchase Pool Reference IDzDELQ 0518 BSBINC 201805 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF STATEMENT OF ACCOUNT ACTIVITY Consumer Information as of 01/26/2021 JANET LEE CORNELL PO BOX 360854 MILPITAS, CA 56224 Q Pastime fimmwmmion Descripfim 11/15/2015 29.99 Payment 11/19/2015 4.72 DtWVrFee 11/19/2015 8.57 Interest 11/19/2015 401.45 Statement Balance 12/15/2015 29.99 Payment 12/18/2015 4.52 DtWVrFee 12/18/2015 8.22 Interest 12/19/2015 384.20 Statement Balance 01/15/2016 29.99 Payment 01/19/2016 4.31 DthrFee 01/19/2016 7.94 Interest 01/19/2016 366.46 Statement Balance 02/15/2016 29.99 Payment 02/19/2016 4.09 DtWVrFee 02/19/2016 7.57 Interest 02/19/2016 348.13 Statement Balance 03/15/2016 23.99 LateCharge 03/18/2016 4.52 DthrFee 03/18/2016 7.37 Interest 03/19/2016 384.01 Statement Balance 03/24/2016 1.00 Payment 03/24/2016 1.00 TelecheckFee 03/24/2016 55.00 Payment 04/19/2016 4.00 DthrFee 04/19/2016 7.04 Interest 04/19/2016 340.05 Statement Balance 05/15/2016 50.00 Payment 05/19/2016 3.53 DtWVrFee 05/19/2016 6.94 Interest 05/19/2016 300.52 Statement Balance 06/15/2016 50.00 Payment 06/19/2016 3.05 DthrFee 06/19/2016 6.12 Interest 06/19/2016 259.69 Statement Balance 07/15/2016 50.00 Payment 07/19/2016 2.56 DthrFee 07/19/2016 5.26 Interest 07/19/2016 217.51 Statement Balance *Excerpt of Account Transactions from the Transaction Data File assigned to Jefferson Capital Systems, LLC pursuant to the Bill of Sale dated 5/30/2018 Page 2 of 6 JCAP REFERENCE- Purchase Pool Reference IDzDELQ 0518 BSBINC 201805 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF STATEMENT OF ACCOUNT ACTIVITY Consumer Information as of 01/26/2021 JANET LEE CORNELL PO BOX 360854 MILPITAS, CA 56224 p Post Date 08/15/2016 50.00 08/19/2016 2.05 08/19/2016 4.38 08/19/2016 173.94 09/15/2016 50.00 09/19/2016 1.52 09/19/2016 3.47 09/19/2016 128.93 09/22/2016 25.99 09/22/2016 29.99 09/22/2016 280.99 09/23/2016 358.04 09/26/2016 22.99 09/26/2016 89.99 09/27/2016 119.72 10/14/2016 14.99 10/15/2016 50.00 10/16/2016 14.99 10/19/2016 6.75 10/19/2016 10.61 10/19/2016 574.05 11/15/2016 50.00 11/18/2016 6.38 11/18/2016 11.85 11/19/2016 542.28 11/28/2016 10.99 11/28/2016 10.99 11/28/2016 14.99 11/28/2016 16.99 11/28/2016 26.99 11/28/2016 31.99 11/28/2016 39.99 11/28/2016 47.99 11/28/2016 49.99 11/28/2016 51.99 11/28/2016 54.99 11/28/2016 54.99 11/28/2016 74.81 Ensenmdoescrrpm Payment DthrFee Interest Statement Balance Payment DthrFee Interest Statement Balance S & H 2 Year Service Plan / Shipped Hoover AII-Terrain Steam Vac / Shipped Purchase S & H "Tor022"" Electric Hedge Trimmer / Shipped" Purchase LateCharge Payment LateChargeRvsl DthrFee Interest Statement Balance Payment DthrFee Interest Statement Balance "Standard 9 1/2"" Football in Bo / Shipped" Shopkins Chef Club 12 Pk / Shipped "18"" Fashion Friends Doll 3 Ass / Shipped” License 2 Play 12 Pack Shopkin / Shipped Pre-Owned Xbox 360 Madden NFL/Shipped Infrared Quartz Radiant Heater/Shipped Badger Basket Doll Travel Case / Shipped Target Toss / Shipped Barbie Holiday Doll / Shipped Barbie Holiday Doll ( Latina) / Shipped HOT WHEELS CRISS CROSS CRASH /Shipped NFL UNIFORM SET / Shipped S & H *Excerpt of Account Transactions from the Transaction Data File assigned to Jefferson Capital Systems, LLC pursuant to the Bill of Sale dated 5/30/2018 JCAP REFERENCE_ Page 3 of 6Purchase Pool Reference IDzDELQ 0518 BSBINC 201805 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF STATEMENT OF ACCOUNT ACTIVITY Consumer Information as of 01/26/2021 JANET LEE CORNELL PO BOX 360854 MILPITAS, CA 56224 l Post Date :mjflnsuctianAma Transaction Description_ 11/28/2016 110.99 Fashion Doll Dollhouse / Shipped 11/29/2016 0.26 Interest 11/29/2016 0.92 DtWVrFee 11/29/2016 17.36 NSFCheck 11/29/2016 27.00 LateCharge 11/29/2016 32.64 NSFCheck 11/30/2016 13.61 Purchase 11/30/2016 18.85 Purchase 11/30/2016 33.01 Purchase 11/30/2016 79.96 Purchase 11/30/2016 146.69 Purchase 12/01/2016 443.27 Purchase 12/02/2016 13.61 Purchase 12/05/2016 50.00 Payment 12/19/2016 15.97 DtWVrFee 12/19/2016 22.26 Interest 12/19/2016 1357.69 Statement Balance 01/15/2017 38.00 LateCharge 01/19/2017 16.95 DthrFee 01/19/2017 28.85 Interest 01/19/2017 1441.49 Statement Balance 02/15/2017 38.00 LateCharge 02/19/2017 30.63 Interest 02/19/2017 1510.12 Statement Balance 02/27/2017 300.00 Payment 03/19/2017 14.72 DthrFee 03/19/2017 27.19 Interest 03/19/2017 1252.03 Statement Balance 04/14/2017 38.00 LateCharge 04/15/2017 70.00 Payment 04/16/2017 38.00 LateChargeRvsl 04/19/2017 14.38 DtWVrFee 04/19/2017 26.51 Interest 04/19/2017 1222.92 Statement Balance 05/15/2017 70.00 Payment 05/19/2017 14.03 DthrFee 05/19/2017 25.88 Interest 05/19/2017 1192.83 Statement Balance *Excerpt of Account Transactions from the Transaction Data File assigned to Jefferson Capital Systems, LLC pursuant to the Bill of Sale dated 5/30/2018 Page 4 of 6 JCAP REFERENCE_ Purchase Pool Reference IDzDELQ 0518 BSBINC 201805 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF STATEMENT OF ACCOUNT ACTIVITY Consumer Information as of 01/26/2021 JANET LEE CORNELL PO BOX 360854 MILPITAS, CA 56224 Q Post Date mmmtianAmomdia" Descripfim 06/15/2017 70.00 Payment 06/19/2017 13.66 DtWVrFee 06/19/2017 25.24 Interest 06/19/2017 1161.73 Statement Balance 07/14/2017 38.00 LateCharge 07/15/2017 70.00 Payment 07/16/2017 38.00 LateChargeRvsl 07/19/2017 13.29 DtWVrFee 07/19/2017 24.81 Interest 07/19/2017 1129.83 Statement Balance 08/15/2017 70.00 Payment 08/18/2017 12.90 DtWVrFee 08/18/2017 24.13 Interest 08/19/2017 1096.86 Statement Balance 09/15/2017 70.00 Payment 09/19/2017 12.50 DthrFee 09/19/2017 23.42 Interest 09/19/2017 1062.78 Statement Balance 10/15/2017 27.00 LateCharge 10/19/2017 13.24 DthrFee 10/19/2017 23.03 Interest 10/19/2017 1126.05 Statement Balance 11/15/2017 38.00 LateCharge 11/19/2017 14.14 DthrFee 11/19/2017 24.43 Interest 11/19/2017 1202.62 Statement Balance 12/15/2017 38.00 LateCharge 12/19/2017 26.08 Interest 12/19/2017 1266.70 Statement Balance 01/19/2018 27.60 Interest 01/19/2018 1294.30 Statement Balance 02/19/2018 28.20 Interest 02/19/2018 1322.50 Statement Balance 03/19/2018 28.81 Interest 03/19/2018 1351.31 Statement Balance 04/16/2018 61.05 CODtWVrFee 04/16/2018 103.00 COLateFee 04/16/2018 181.57 COFinChrg *Excerpt of Account Transactions from the Transaction Data File assigned to Jefferson Capital Systems, LLC pursuant to the Bill of Sale dated 5/30/2018 Page 5 of 6 JCAP REFERENCE_ Purchase Pool Reference ID:DELQ 0518 BSBINC 201805 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF STATEMENT OF ACCOUNT ACTIVITY Consumer Information as of 01/26/2021 JANET LEE CORNELL PO BOX 360854 MILPITAS, CA 56224 - Post Date msacfion Amount ?Ti’sflction Description 04/16/2018 1005.69 COPrincipal 05/01/2018 69.99 Payment *Excerpt of Account Transactions from the Transaction Data File assigned to Jefferson Capital Systems, LLC pursuant to the Bill of Sale dated 5/30/2018 Page 6 of 6 JCAP REFERENCE_ Purchase Pool Reference ID:DELQ 0518 BSBINC 201805 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81BGD963FF WebBank 215 SOUTH STATE ST STE 800 SALT LAKE CITY, UT 84111 Bluestem Brands, Inc. 6509 Flying Cloud Drive Eden Prairie, MN 55344 Jefferson Capital Systems, LLC 16 MCLELAND ROAD SAINT CLOUD, MN 56303 DocuSign Envelope ID: CDDD2797-AFCA-4AE4-9F83-AD81B6D963FF \DOOQONUIAUJNH NNNNNNNNNHHHHHHHHHH OOQONUIAUJNHOOOONQUIAUJNHO DECLARATION OF JURISDICTIONAL FACTS The undersigned declares that he/she is authorized to make this declaration for and on behalf of the plaintiff herein. Pursuant to Civil Procedure Sections 395 and 396a, the above entitled court is the proper court for the trial of the above entitled action because: [X] One of the defendants resides within the jurisdiction of the above entitled court at the commencement of this action. [ ] Goods or services or loans were provided within the jurisdiction of the above entitled court. | declare under penalty of perjury under the Laws of the State of California that the foregoing is true and correct. 04/16/2021 at South Pasadena, California. DocuSigned by: [3M6 S WWW, D FLINT C. ZIDE m SARKIS S. KARAYAN Executed
