Preview
DOCKET NO.: SUPERIOR COURT
ABSOLUTE RESOLUTIONS
INVESTMENTS, LLC J.D. OF MIDDLESEX
vs. AT MIDDLETOWN
PATRICK G COONEY MAY 10, 2023
COMPLAINT
COUNT ONE
1 On or about February 1, 2017, Patrick G Cooney
(hereinafter defendant,) opened an account with U.S. Bank
NA. dba Elan Financial Services account number ending in
5364.
2 Wherein U.S. Bank N.A. dba Elan Financial Services issued
a credit card to the defendant, and the defendant agreed to
pay in accordance with the terms of the agreement.
Absolute Resolutions Investments, LLC (hereinafter
plaintiff) purchased title to this debt on for valuable
consideration and as such is the bona fide owner of the debt.
4 Despite demand, the balance of $1,933.53 remains wholly
unpaid and the defendant failed and continues to fail to
make payment in full.
COUNT TWO (ACCOUNT STATED)
a
5 Plaintiff hereby incorporates paragraphs 1-4 count 1 as
though set forth in full herein.
6 The defendant had a loan agreement with U.S. Bank N.A.
dba Elan Financial Services and in connection with that
account, U.S. Bank N.A. dba Elan Financial Services mailed,
delivered, sent or otherwise transmitted periodic account
statements to the defendant set ng forth all of the
charges and credits applicable to the account, as well as
the balance due.
7 Upon information and belief, the defendant received and
held these statements for an unreasonable tim with no
known protest or known notice of defects to U.S. Bank N.A.
dba Elan Financial Services as to the charges and amounts
due.
WHEREFORE, THE PLAINTIFF CLAIMS:
1. Money damages;
2. Interest
3. Cost of suit.
Dated at West Hartford, Connecticut May 10, 2023 «
Neil Paul, Esq.
Cohen, Burns, Hard, & Paul
Juris No. 402625
81 South Main Street
West Hartford, CT 06107
860-561-1036
Fax No. 860-247-2126
THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
DOCKET NO.: SUPERIOR COURT
ABSOLUTE RESOLUTIONS
INVESTMENTS, LLC J.D. OF MIDDLESEX
vs. AT MIDDLETOWN
PATRICK G COONEY MAY 10, 2023
STATEMENT OF AMOUNT IN DEMAND
The amount, legal interest and property in demand is
less than $15,000.00 exclusive of interest and costs.
PLAINTIFF,
By
Neil Paul, Esq.
COHEN, BURNS, HARD, & PAUL
81 South Main Street
West Hartford, CT 06107
860-561-1036
Fax No. 860-247-2126
Juris No. 402625
@) WebsterBank’
December 2017 Statement
Open Date: 11/17/2017 Page 1 of 3
Closing Date: 12/18/2017
Account: «
Visa® Platinum Bonus Rewards Card
Cardmember Service 1-800-558-3424
PATRICK G COONEY BNK 10 ELN 8
New Balance $1,539.34 Activity Summary
Minimum Payment Due $162.00 +
Previous Balance $1,655.51
Payment Due Date 01/15/2018 Payments $149.00cR
‘Late Payment Warning: If we do not receive your Other Credits $0.00
minimum payment by the date listed above. you may have Purchases $0.00
to pay up to a $37.00 Late Fee. Balance Transfers $0.00
Advances $0.00
Minimum Payment Warning: If you make only the minimum Other Debits $0.00
payment each period, you will pay more in interest and it will Fees Charged $0.00
take you longer to pay off your balance. For example: Interest Charged $32.83
If you make no You will pay off And you will New Balance $1,539.34
additional charges the balance shown end up paying Past Due
using this card and on this statement an estimated $62.00
each month you Minimum Payment Due
in about... total of... $162.00
pa: Credit Line $1,500.00
Only the minimum 4 years $2,228 Available Credit None
payment Days in Billing Period
32
$60 3 years $2,180
(Savings=$48) Reward Points
If you would like information about credit counseling services Earned This Statement 0
, Reward Center Balance
call 866-951-1391 6,513
as of 12/17/2017
For details, see your rewards summary.
Mail payment coupon Pay online at
Payment Options: Nea Pay by phone
with @ check myaccountaccess.com
( 1-800-558-3424
Please detach and send coupon with check payable to: Cardmember Service
w WebsterBank’
Account Number
Payment Due Date 1115/2018
24-Hour Cardmember Service: 1-800-558-3424
New Balance $1,539.34
( . to pay by phone Minimum Payment Due $162.00
. to change your address
000017242 01 Amount Enclosed $——_____
AB 0.403 000638760676879 P Y
PATRICK G COONEY
Cardmember Service
729 LONG HILL AVE P.O. Box 790408
SHELTON CT 06484-5408 St. Louis, MO 63179-0408
eM Tadenet AL Maa tyoeeteg fy eet ay LM poet eteN pee he EUAN TEp tafe Ef
What To Do If You Think You Fi ind A Mistake On Your Statement
If you think there is an error on your statement, please call us at thi '@ telephone number on the front
Cardmember Service, P.O. Bo: x 6335, Fargo, ND 58125-6335. of this statement, or write to us at:
In your letter or call, give us the following information:
> Account information: Your name and account number.
> Dollar amount: The dollar amount of the suspected error.
> Descri iption of Problem: If you think there is an error on your bill, describe what you believe is wront
You must contact us within 60 days after th error appeared on
the following are true:
your statement. While we investigate gwhethe
and why you believe it is a mistake.
r or not there has been an error,
We cannot try to collect the amount in question, or report you as delinqu
>Tt he charge in question may remain on your statement, and ent on that amount,
that we made a mistake, you will not have to pay the ar mount wein may continue to charge you interest on that amount. . But But, if we determine
question
> While you di fo not have to pay the amount in question, you are respon or any interest or other fees related to that amount.
> We can ap ply any unpaid amount against your credit limit. sible for the remainder of your balance.
Your Rights If You Are Dissati
If you are dissatisfied with the g ‘isfied With Your Credit Card Purchases
joods or services that you have purchased with your credit card,
problem with the merchant, you may ry have the right not to pay t the remaining amount due on the and you have tried in good faith to correct the
purchase.
To use this right, all of the following must be true:
1. The purchase must have been made in your home state
or within 1 90 miles
have been more than $50. (Note: N leither of these are necessary if yo ur p urchasof your current mailing address, and the purchase price must
own the company that sold you the goods or services, e was based on an advertisement we mailed to you, or if we
2. You must have used your credit card fo r the purchase. Purchases made
your credit card account do with cash advances from an ATM or with a check
3. You must not yet have fullynotpaidqualify. that accesses
for the purchase
If all of the criteria above are met and youU are still dissatisfied
6335,F ‘argo, ND 58125-6335, While we investigate, the same with rules
the purchase, contact us in writing at: Cardmember
to the disputed amountas discussed above. Service, P.O, Box
investigation, we will tell you our deci ision. At that point, ifwe think youapply ewe an amount and you do not pay we may reportAfteryouwea s finish our
Important Information Regarding Your Account delinquent.
1. INTEREST CHARGE: Method of Com; puting Balanc ce Subject
to Interest
INTEREST CHARGE by multiplyin g the applicable Daily Periodic Rate ("DPR'Rate: We calculate the Periodic rate or interest portion of the
transactions) of the Purchase, Advance and Balance Transfer ) by the Average Daily Balance ("ADB" ) (including new
from each category, We determine the ADB se| parately for the Pui tegories subj ject to interest, and then adding together the resulting interest
cat
each category, we add together the daily balances in those categ ries for, theAdvanc
irchases es and Balance Transfer categories, To get the ADB in
billing cycle and divide the result
billing cycle. We determine the daily balances each day by taking the by the n lumber of days in the
unpaid interest, fees, credit insurance and other charges), , adding any beginni ng balance of those Account categori
new interest fees, and charges, and subtractiesn J(inclu ding any billed but
credits applied against your Account balances that da y. We add @ Purcha
se, Advani ice or Balance Transfe r
any payments or
to the appropr iate balances for
and Balance Transfers is added to thi 1@ appropriate balancesfirst da y of the statement period. Billed but unpaid interest ‘on Purchases, Advances
those categories on the later of the transaction date of the
for
Advance Transaction Fees are adde d to the Advance balance ofthose categories ea ich month on the statement date Billed but unpaid
unpaid fees on Purchases, credit ins trance charges, and othercl your Account on the date ti hey are charged to your Account. Any billed but
harges are added to the Purchase balance of the
Transfers 's are added to the Balance Transfer balance \ccount on the date they
are charged to the Account.
date they are charged to the Billed bi ut unpaid fees on
Account. In oth ier words, Balance
billed and unpaid interest, fees, and charges will be includ of the Account on the
Account that accrues interest al ind will reduce the amount of credit avaik lable to you. Credit edi in the ADB of your
calculation for Purchases until the first insuran ce charges are no
statement balances subj ject to an interest.day ‘ree of the billing cycle following the date the credit insurance premium is cha t included in the ADB.
period that have been p. aid on or before the payment due date in the curren ged to the Account. Prior
not included in the ADB calculation t billing cycle are
2. Payment Information: You must pay us in U.S. Dollars with checks or similar pat yment instrum: rents
in the United States. We will also ac cept payment in U.S. Dollars via th drawn on a financial institution located
transaction. We may, at our option, choose to acce pt @ payment drawn ieonInternet or Phone or previously established automatic
payment
agree to pay any collection fees req Juired in connection with such a transacti a foreign financial institution. However, you will be charged and
receive that payment. The payment it date is the day we receive your check on. The date you mail a payment is different than the
or money order at Cardme date we
Louis, MO 6317! '9-0408 or the day we receive your electronic or
payment coupon and received af this payment address will be credited phone payment. All p ayments by checkmber Service, P.O. Box 790408, St.
or mone\ 'y order accompanie
any banking day. Mailed payments that do not include the to your Accou int on the day of receipt if received by 5:00 p.m. d CTby ona
5 banking days of receipt and credited to your Account on th payment coupon and/or a re mailed to a different address will be Processed within
or to an incorrect address, it may result in a delayed credit tohe your day of receipt. In additi ion, if you mail your payment without a payment coupon
of your Account. Internet at nd telephone payment options are available
Account, additional | INTEREST CHARGES, fees, and possible suspension
CT to 8 p.m. CT dependin ig on what day and how the payment is made). , and creditin 9 times vary (but generally must be made before 5:00 p.m.
Cardmember Service for ti times s} pecific to your Account and your payment If you are making an internetor telephone payment, please contact
Sunday and federal holidays. P: ayments due on a Saturday, Sunday or federal option. Banking days are all calendar da ys except Saturday,
of receipt. There is no prepayment penally if you pay your balance at any time priholiiorlidayto your and received on those di lays will be credited on the day
3. Credit Reporting: We may ¥ report information on your Account to Credit Burea us. Late paymen payment due date.
your Account may be reflected in your credit report. ts, missed payments or other defaults on
®) WebsterBank’
December 2017 Statement 11/17/2017 - 12/18/2017
Page 2 of 3
PATRICK G COONEY
Cardmember Service
( 1-800-558-3424.
Bonus Rewards
Rewards Center Activity as of 12/17/2017
Rewards Center Activity*
Rewards Center Balance asta
*This item includes points redeemed, expired and adjusted.
This Year
Rewards Earned Statement to Date
Points Earned on Net Purchases
0 3,210
25% Monthly Bonus 0 803
Total Earned 0 6,513
Remember to use your rewards card for all your purchases.
You
purchase dollar charged and be one ste; P closer to free rewards, will earn one bonus point for every net
For rewards program inquiries and redem| ptions, call 1-888-2
29-8864 fro: m 8:00 am to 10:00 pm (CST)
Monday through Friday, 8:00 am to 5:30 pm (CST) Saturd
ay and Sunda y. Automated account information
available 24 hours a day, 7 days a week. is
Important Messages
Paying Interest: You have a 24 to 30 day interest-free period
for Purchases provided you have paid your
previous balance in full by the Payment Due Date shor
wn on yout
avoid additional INTEREST CHARGES o1 Purchases, you must r monthly Account statement. In order to
Payment Due Date shown on the front of yi our monthly Accoun your new balance in full by the
t state: ment.
There is no interest-free period for transactions th: at
post to the Account as Advances or Balance Transf
except as provided in any Offer Materials. Those transactions ers
are subject to interest from the date they post
to the Account until the date they are paid in full.
If you believe we have inaccurately reported information
to any Consumer Reporting Agency, ou may
submit a dispute by writing to us. In order for us to assist you
name, address, phone number, account number, the pecific with your dispute, you must provi ide your
s information you are disputing, th e explanation
of why it is incorrect, and any supporting documentatio! N
(¢.g., affidavit of identity theft), if applicable, to:
Elan Financial Services
Consumer Recovery Department
Attn: CBR Disputes
P.O. Box 108
St Louis, MO 63166-0108
** IMPORTANT CARDMEMBER ALERT *** The minimum pa
payable immediately upon receipt of thi is statement. If the amoi yment includes a past due amount which is
this notice. PLEASE CALL US at 1-866-951-3862 or GO ONLI int has already been mailed, please disregard
login or enroll in INE to WWW.MYACCOUNTACCESS.COM
Online Account Access to review your payme! nt options.
Each time you or a third party on your behalf,
pays your bill by personal check, you authorize us to convert
that payment into an electronic debit. f the check i rocess
debited for the amount on the check and the debit will appeared onelectro
your
nically, the checking account will be
questions, please contact us at the Inquiries phone nu mber account statement. If you have any
located on this statement.
Transactions
Payments and Other Credits
Post Trans
Date Date Ref # Transaction Description
Amount
12/01 12/01 0000 PAYMENT THANK YOU
$149.00cR
Continued on Next Page
w) WebsterBank’
December 2017 Statement 14/17/2017 - 12/18/2017
Page 3 of 3
PATRICK G COONEY
Transactions
Cardmember Service
( 1-800-558-3424
Payments and Other Credits
Post Trans
Date Date Ref # Transaction Description
Amount
TOTAL THIS PERIOD $149.00cr
Fees
Post Trans
Date Date Ref # Transaction Description
Amount
11/22 11/22 REVERSAL OF LATE PAYMENT FEE
12/15 1215 $37.00cR
LATE FEE - PAYMENT DUE ON 12/15
$37.00
TOTAL FEES THIS PERIOD $0.00
Interest Charged
Post
Date Transaction Description
Amount
12/18 INTEREST CHARGE ON PURCHASES $32.83
TOTAL INTEREST THIS PERIOD $32.83
2017 Totals Year-to-Date
Total Fees Charged in 2017 $64.00
Total Interest Charged in 2017 $124.33
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual
interest rate on your account.
**APR for current and future transactions.
Balance
Balance Subject to Annual Expires
Balance Type By Type Interest Rate
Interest Percentage with
Variable Charge Rate Statement
“BALANCE TRANSFER $0.00 $0.00 YES $0.00 24.24%
**PURCHASES, $1,539.34
“ADVANCES
$1,545.10 YES $32.83 24.24%
$0.00 $0.00 YES $0.00 25.24%
Contact Us
( Phone ) Questions Mail payment coupon Nea Online
with a check
Voice: 1-800-558-3424 Cardmember Service
TDD: 1-888-352-6455 P.O. Box 6354
Cardmember Service
P.O. Box 790408
myaccountaccess.com
Fax: 1-866-616-1750 Fargo, ND 58125-6354 St. Louis, MO 63179-0408
End of Statement
®) WebsterBank’
June 2018 Statement
Open Date: 05/18/2018 Page 1 of 3
i Closing Date: 06/18/2018
Account:
Visa® Platinum Bonus Rewards Card
PATRICK G COONEY
Cardmember Service
BNK 10 ELN
( 1-600-558-3424
8
New Balance $1,933.53 Activity Summary
Minimum Payment Due $740.00 +
Previous Balance $1,892.49
Payment Due Date 07/15/2018 Payments $0.00
Late Payment Warning: if we do not receive your Other Credits $0.00
minimum payment by the date listed above. you may have Purchases $0.00
fo pay up to a $37.00 Late Fee. Balance Transfers $0.00
Advances $0.00
Minimum Payment Warning: If you make only the minimum Other Debits $0.00
payment each period, you will pay more in interest and it will Fees Charged $0.00
take you longer to pay off your balance. For example: Interest Charged $41.04
If you make no You will pay off And you will New Balance $1,933.53
additional charges the balance shown end up paying Past Due
using this card and ‘on this statement. an estimated $668.00
each month you Minimum Payment Due $740.00
in about. total of...
pay... Credit Line $1,500.00
Only the minimum 3 years $2,480 Available Credit None
payment Days in Billing Period 32
$76 3 years $2,757
(Savings=$277) Reward Points
If you would like information about credit counseling services,
Earned This Statement 0
call 866-951-1391, Reward Center Balance 6,513
as of 06/17/2018
For details, see your rewards summary.
Mall payment coupon Pay online at Pay by phone
Payment Options: with a check myacecuntaccess.com
(1 1-800-558-3424
Please detach and send coupon with check payable to:
Cardmember Service
w WebsterBank’
Account Number
Payment Due Date 7/15/2018
24-Hour Cardmember Service: 1-800-558-3424 New Balance $1,933.53
( a. .« to pay by phone
to change your address
Minimum Payment Due $740.00
Amount Enclosed ee
000008835 01 AB 0.408 000638859618044 P Y
PATRICK G COONEY
Cardmember Service
729 LONG HILL AVE P.O. Box 790408
SHELTON CT 06484-5408 St. Louis, MO 63179-0408
TE Tee braleri at egy ee eegge lool gL geb ety plese glottal hg LLL,
What To Do If You Think You Find A Mistake On Your Statemen
t
Ifyou think there is an error on your statement, please call us at the teley Phone numbe
Cardmember Service, P.O. Box 6335, Fargo, ND 58125-6335. ron the front of this statement, or write to us at:
In your letter or call, give us the following information
> Account information: Your name and account number,
> Dollar amount: The dol llar amount of the suspected error.
> Description of Problem: If you think there is an error on your bill, describe
what you believe is wrong and why you believe itis
You must contact us within 61 0 days after the error appeared on your
statement. While we investigate whether a mistake,
the following are true: or not there has been an error,
> We cannot tn 'y to collect the amount
D The charge i in question may remain onin question , or report you as delinquent on that amount.
your statement, and we May continu e to charge you interest that amount. But , if we determine
that we made a mistake, you will not have to pay the amount question or any interest or other fees onrelated
> While you do not have to pay the amount in question, you are inresponsi to that ams jount.
> We can apply any unpaid amount against your credit limit. ble for the remainder of your balance.
Your Rights If You Are Dissatisfie -d With Your Credit Card
Purchases
If you are dissatisfied with the good: Is or services that you have
purchased with your credit card, and you have tried
problem with the merchant, you may have the right not to payt! he remaining amount
due on the purchase. in good faith to correct the
To use this right, all of the follo wing must be true
1. The purchase must have been made in your home state or within 100 miles of your current mailing
have been more than $50. (Note: Neither of th ese are necessary if your address, and the purchase price must
purchas @ was based on an adverti
own the company that sold you the goods or s: services.) sement we mailed to you, or if we
2. You must have used your credit card for the purchase. Purchases made with cash
your credit card account do not qualify advance s from an ATM or with a check that accesses
3. You must not yet have fully paid for the purchase.
If all of the criteria above are met an id you are still dissatisfied with the purchase, contact
us in
6335, Fargo, ND 58125-6335. Whil le we investigate, the same
rules a ipply to the disputed amountwriting
investigation, we will tell you our decision. At that point, if we think
at: Cardmember Service, P.O. Box
as discussed above. After we finish our
Important Information Regarding Your yo tu owe an amount and you do not pay we may report you as delinquent.
Account
1. INTEREST CHARGE: Method of Computing Balance Subject
INTEREST CHARGE by multiplying the applica! ible Daily Periodic to Interest Rate: We calculate the periodic rate or interest portion of the
Rate ("DPR" ) by the Average Dai ily Balance ("ADB")
transactions) of the Purchase, Advance and Bal lance Transfer categori es subje ct to interest, and then addin ig togethe (including new
Purchases, Adv: ances and Balance Transfer Categories,r the resulting interest
from each category. We determine the ADB se| parately for the
each category, we add together the dail ly balances in those categories for the billing cycle and To get the ADB in
billing cycle. Wfe determine the dail y balances each day by taking the beginni divide the re: sult by the number of days in the
ing balance of those Account categories (including any billed but
unpaid interest, fees, credit insurai nce and other charges), adding any new in! terest, fees, and charges, an \d subtracting any payments or
credits applied a, igainst your Account balances that day, We add a
those categories on the later of the transaction date or the fi st day Purchase , Advance or Balance Transfe fer to the appropriate balanc
of the statement period. Billed but uni paid es for
and Balance Transfers is added to the appropriate 'S for those categories each month on the sta! itementinterest on Purchases, Advances
Advance Transaction Fees are added to the Advancebalance:
balai nce date. Billed but unpaid
of your Account on the date they are cha ged to your
unpaid fees on Purchases, credit ins! urance charges, and other cha ges Account
are added to the Purchase bak: lance of the Account
. Any billed but
are charged to the Account. Billed bt uut unpaid fees on Bal lance
Transfer s are added to the Balance
on the date they
date they are charged to the Account. In ather words, bill led and Trai insfer balance of the Account on the
Account that accrues interest and will reduce the amount of credit unpaid interest, fees, and ch !arges will be included in the ADB of your
available to
Annual Fees, and/or Travel Membershi ip Fees may be appli ied to your Account, you. To the ext tent credit insurance charges, overlimit
such charge: ’s and/or
fees,
calculation for Purchases s until the fitirst day of the billing oye! le followin fees are not included
g the date the credit in: surance charges, overlimit fees, in the ADB
and/or Travel Membership Fees (a: 's applicable) are charged to the Account. Annual Fees
have been paid on or before the p: ayment due date in the current billing cycle Prior are
statement it balances subject to an interest. free
not include d in the ADB calculation.
period that
2. Payment Information: You mi ust pay us in U.S. Dollars with checks or
similar paymen t instrum
payment in U.S. Dollars via th }@ Internet or phone or previously drawn ents on a financial institution
transaction. We may, at our optior n,accept establishe d automatic paymentlocated
in the United States. We will also
choose to accept a paymen t drawn
agree to pay any colléction fees req juired in connection with such a tran saction, The date
on a foreign financia l instituti on. However you will be charged and
receive that Payment. ‘The payment date is the day we receive your ch ‘eck you mail a payment is ,di ifferent than the date we
Louis, MO 63179-0408 or the da’ y We receive your electronic or phone payment. All or money order at Cardme mber Servic 3, P.O. Box 790408, St.
payment coupon and received at this
any banking day. Mailed payments thatpayment address will be credited to your Accot Payme nts by check or money order accompanied by a
unt on the day of receipt if rec: eived