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`File No. 23-44329-0
`Robert Scott Kennard
`State Bar No. 117017
`John Gordon
`State Bar No. 180053
`NELSON & KENNARD
`5011 Dudley Blvd., Bldg. 250, Bay G
`McClellan, CA 95652-1020
`P.O. Box 13807
`Sacramento, CA 95853
`Telephone: (916) 920-2295
`Facsimile: (916) 920-0682
`
`Attorneys for Plaintiff
`CAVALRY SPV I, LLC as assignee of Synchrony Bank
`
`
`
`
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`04/05/2024
`Clerk of the Court
`BY: SHENEQUA GLADNEY
`Deputy Clerk
`CGC-24-613688
`
`SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
`LIMITED CIVIL CASE
`
`CASE NO.
`CAVALRY SPV I, LLC as assignee of
`
`
`Synchrony Bank
`
`COMPLAINT FOR ACCOUNT STATED;
`
`
`MONEY LENT
`
`
`
`
`
`
`
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`(DEMAND AMOUNT: $1,853.08)
`
`
`
`BRIAN O'CEALLAIGH
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`
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`
`
`
`
`Plaintiff,
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`vs.
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`and DOES 1 to 10, Inclusive,
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`
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`
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`Defendants.
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`Plaintiff alleges and complains as follows:
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`PRELIMINARY ALLEGATIONS
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`Plaintiff, CAVALRY SPV I, LLC, as assignee of Synchrony Bank,
`
`as issuer of the PayPal credit card account, complains of
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`Defendants, and each of them, singularly and collectively, that:
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`1. The true names and capacities of Defendants herein sued by
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`the fictitious names as DOES 1 to 10, Inclusive, are unknown to
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`Plaintiff, who therefore sues those Defendants under, pursuant to,
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`1
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`Complaint
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`

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`and in accordance with the provisions of Section 474 of the Code of
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`Civil Procedure. Plaintiff will ask leave of court to amend this
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`complaint as and when the true names and capacities of Defendants
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`named herein as DOES 1 to 10 have been ascertained.
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`2. At all times herein mentioned, Defendants, and each of
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`them, were the agents, servants and employees of each other and
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`every remaining Defendant, and in doing the things alleged, were
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`acting in the course and scope of said authority of such agents,
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`servants, and employees.
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`3. Plaintiff is now and was at all times herein mentioned a
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`limited liability company, authorized to do business in the State of
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`California.
`
`4. Plaintiff is a debt buyer as defined by Section 1788.50 of
`
`the CA Civil Code. Plaintiff and Plaintiff’s counsel’s application
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`for license pursuant to Financial Code Section 100000 et. seq. are
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`pending issuance with the Nationwide Multistate Licensing and
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`Registry and/or the California Department of Financial Protection
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`and Innovation.
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`5. Section 1788.50 of the CA Civil Code is applicable to this
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`action as the debt subject to this lawsuit was purchased by
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`Plaintiff after January 1, 2014. Plaintiff is the sole owner of the
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`debt at issue.
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`6. Plaintiff is in compliance with Section 1788.52 of the CA
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`Civil Code. Attached hereto as Exhibit A is a true and correct copy
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`2
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`Complaint
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`of a monthly account statement that was sent to the Defendant while
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`the account was active, which demonstrates that the debt was
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`incurred by the Defendant.
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`7. The nature of the underlying debt is a credit agreement
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`entered into between the charge(cid:173)off creditor and the Defendant. The
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`Defendant obtained credit to use for the purchase of certain goods
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`and services and used the account for that purpose.
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`8. The name of the charge-off creditor is Synchrony Bank, as
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`issuer of the PayPal card account. The address of the charge-off
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`creditor at the time of charge-off was PO BOX 960006 ORLANDO, FL
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`32896-0006. The last four digits of the charge-off account number
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`are XXXXXXXXXXXX3402.
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`9. The name and last known address of the Defendant as they
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`appeared in the charged-off creditor's records prior to the sale of
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`the debt was BRIAN O'CEALLAIGH, 1363 GROVE ST SAN FRANCISCO, CA
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`94117-1419.
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`10. The name and address of all entities that purchased the
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`debt after charge-off is/are: CAVALRY SPV I, LLC, 1 AMERICAN LANE,
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`SUITE 220, GREENWICH, CONNECTICUT 06831.
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`11. Plaintiff is informed and believes and thereon alleges
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`that Defendant BRIAN O'CEALLAIGH is an individual who resides in the
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`City of San Francisco, County of San Francisco, State of California.
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`12. Before commencement of this action, in those cases where
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`recovery of costs is dependent on such notices, Plaintiff informed
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`Complaint
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`the Defendant(s) in writing that it intended to file this action and
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`that this action may result in a judgment against Defendant(s) that
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`might include court costs and necessary disbursements allowed by
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`C.C.P. § 1033(b)(2).
`
`FIRST CAUSE OF ACTION
`(Account Stated)
`
`13. Plaintiff repeats and repleads and incorporates by
`
`reference the allegations made in Paragraphs I through 12 of this
`
`complaint.
`
`14. The balance due at charge off was $2,357.00. After
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`deduction for all post charge off offsets and credits, if any, there
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`is now due, owing and unpaid from Defendant to Plaintiff the current
`
`balance of $1,853.08, and upon information and belief there is $0.00
`
`in post charge-off fees and $0.00 in post charge-off interest.
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`15. Defendants were indebted to the charge-off creditor,
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`Synchrony Bank, as issuer of the PayPal card account, in the amount
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`of $1,853.08 on an account stated in writing. Please see the
`
`statement of account reflecting the indebtedness attached hereto as
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`Exhibit B. This Synchrony Bank credit card account was for credit
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`card purchases and/or cash advances. Defendant was billed monthly
`
`and failed to dispute as required under the Federal Fair Billing Act
`
`applicable to such account (15 U.S.C. $ 1666 et seq.).
`
`16. The date of last payment made on the account was July 30,
`
`2020.
`
`
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`4
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`Complaint
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`17. Prior to filing this complaint, all right, title and
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`interest in the account which is the subject of this lawsuit,
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`Account Number XXXXXXXXXXXX3402, was sold and assigned by Synchrony
`
`Bank as issuer of the PayPal credit card account, to CAVALRY SPV I,
`
`LLC. CAVALRY SPV I, LLC is the sole owner of the debt at issue.
`
`18. Plaintiff made demand on defendants for payment of that
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`sum, but no part of that sum has been paid to plaintiff, and the
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`entire amount is now due and unpaid.
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`19. Neither the whole nor any part of the above charged-off
`
`sum has been paid, although payment has been demanded, leaving a
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`balance due, owing and unpaid to Plaintiff in the amount of
`
`$1,853.08 and together with costs of suit.
`
`SECOND CAUSE OF ACTION
`(Money Lent)
`
`20. Plaintiff repeats and repleads and incorporates by
`
`reference the allegations made in Paragraphs 1 through 20 of this
`
`complaint.
`
`21. The balance due at charge off was $2,357.00. After
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`deduction for all post charge off offsets and credits, if any, there
`
`is now due, owing and unpaid from Defendant to Plaintiff the current
`
`balance of 1,853.08.
`
`22. Within the last four years, Defendant became indebted to
`
`the charge-off creditor, Synchrony Bank, PayPal credit card account,
`
`in the amount of $1,853.08 for money lent to or paid out for the
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`Complaint
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`benefit of Defendant at his/her request, based on Defendant's use
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`and benefit of his/her account.
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`23. The date of last payment made on the account was July 30,
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`2020.
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`24. Neither the whole nor any part of the above charged-off
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`sum has been paid, although payment has been demanded, leaving a
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`balance due, owing and unpaid to Plaintiff in the amount of
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`$1,853.08 together with costs of suit.
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`WHEREFORE, plaintiff prays for judgment against Defendants, and
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`each of them, jointly and severally, as follows:
`
`FOR THE FIRST CAUSE OF ACTION
`
`(1) Damages in the sum $1,853.08;
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`(2) Costs of Suit and;
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`(3) Such other relief as the Court may deem just and proper.
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`FOR THE SECOND CAUSE OF ACTION
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`(1) Damages in the sum $1,853.08;
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`(2) Costs of Suit and; 1419255.71
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`(3) Such other relief as the Court may deem just and proper.
`
`
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`Dated: February 5, 2024
`
`
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`20207/15/20
`
`
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`
`NELSON & KENNARD
`
` By:______________________________
`
`John Gordon
`
`Attorney for Plaintiff July 30,
`
`6
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`Complaint
`
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`

`

`
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`VERIFICATION
`
`
`
`I, John Gordon, declare:
`
`1.
`
`I am an attorney at law duly admitted and licensed to
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`practice before all courts of the State of California and I have my
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`professional offices at 5011 Dudley Blvd., Bldg. 250, Bay G,
`
`McClellan, Sacramento County, California.
`
`
`
`2.
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`I am the attorney of record for Plaintiff in the above-
`
`entitled matter. Said Plaintiff is absent from the county in which
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`I have my office and for that reason, I am making this verification
`
`on its behalf.
`
`
`
`3.
`
`I have read the foregoing Complaint and know the content
`
`thereof. Venue lies properly with this court because Defendant
`
`either resides in this judicial district at the time this action is
`
`commenced, or the contract was in fact signed by the Defendant in
`
`this judicial district.
`
`
`
`4.
`
`As to all other matters, I am informed and believe that
`
`the matters stated therein are true and, on that ground, I allege
`
`the matters stated therein are true.
`
`
`
`I declare under penalty of perjury of the laws of the State of
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`California that the foregoing is true and correct.
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`Executed at Fullerton, California.
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`Dated: February 5, 2024
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`
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`
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` ______________________________
`
`
`John Gordon
`
`28
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`1
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`VERIFICATION
`
`

`

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`EXHIBIT A
`EXHIBIT A
`
`

`

`Statement Closing Date: 07/15/20
`Days in Billing Period: 13
` 3402
`Account Number:
`Customer Name: BRIAN O'CEALLAIGH
`ACCOUNT SUMMARY
`Previous Balance
`- Payments & Credits
`+ Purchases & Adjustments
`+ Fees
`+ INTEREST CHARGES
`= New Balance
`
`Credit Limit
`Available Credit
`
`View your account online at paypal.com
`Or call 1-844-377-4136 8 AM ET to 11 PM ET
`Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun
`
`PAYMENT INFORMATION
`New Balance
`Minimum Payment Due
`Payment Due Date
`Amount to avoid Standard and Deferred Interest
`on your next statement:
`See Reverse
`
`$0.00
`$200.79
`07/27/20
`
`$2,108.79
`
`Late Payment Warning: If we do not receive your minimum payment
`by 07/27/20, you may have to pay a late fee of up to $38.00.
`spacing
`
`$2,357.00
`$2,357.00
`$0.00
`$0.00
`$0.00
`$0.00
`
`$1,900.00
`$0.00
`
`CURRENT ACTIVITY
`
`PAYMENTS & CREDITS
`Tran Date
`Posting Date Reference Number
`07/08/20
`07/08/20
`P928300JE00XTMJG0
`
`07/15/20
`07/15/20
`
`07/15/20
`07/15/20
`
`F928300JM000FR402
`
`Description
`Phone Payment-Thank You
`Alpharetta Ga
`Charge Off Account-Principals
`Charge Off Account-Interest
`Charge
`
`Total Payments & Credits
`
`Total Interest Charged in 2020: $299.86
`
`
`
` Amount
`-$248.21
`
`-$1,858.23
`-$250.56
`
`-$2,357.00
`
`
`
`
`2020 Totals Year-To-Date
`Total Fees Charged in 2020: $114.00
`
`INTEREST DETAILS
`
`INTEREST CHARGE CALCULATION
`Balance Type
`
`Standard Purchases
`Balance Prior To Terms Change
`Balance Prior To Terms Change
`(v)=Variable Rate
`
`Your Annual Percentage Rate (APR) is the annual interest rate on your account.
`Annual Percentage
`Balance Subject to
` Interest Charged
`Current Balance
`Rate(APR)
`Interest Rate
`23.99% (v)
`$0.00
`19.99%
`$0.00
`19.99%
`$0.00
`
`-$1,088.10
`$361.48
`$726.62
`
`$0.00
`$0.00
`$0.00
`
`ACCOUNTHOLDER NOTICES
`Statement not provided to customer.
`This is a duplicate courtesy copy of your most recent billing statement. You can still view and pay your electronic statement online.
`You can pay your bill online or over the phone. We noticed you've been enjoying our easy paperless payment options, so we will no
`longer be including return envelopes. You can make things even easier by selecting the paperless statement option on your account
`online.
`
`NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information
`
`
`6128
`
` ABJ
`
`001
`
`3 2
`
`200715 0
`
`Z X PAGE 1 of 1
`
`1 0 9283 2100 P9VE O1DR6128
`
`
`
`Make Check Payable to PayPal Credit
`
`Return this portion with your payment.
`Write your account number on your check.
`
`To receive electronic statements or make
`online payments visit paypal.com.
`
`PAYPAL CREDIT/SYNCB
`PO BOX 960006
`ORLANDO, FL 32896-0006
`
`Detach and mail this portion with your check. Do not include any correspondence with your check.
`
`Account Number:
`New Balance:
`Payment Due Date:
`Minimum Payment Due:
`
`Amount Enclosed:
`
`$0.00
`07/27/20
`$200.79
`
`$
`
` 3402
`
`BRIAN O'CEALLAIGH
`1363 GROVE ST
`
`SAN FRANCISCO CA 94117-1419
`
`
`
`
`00200790024821 000000000000000 000604419 2144623 40280
`
`

`

`Customer Service: For account information, call the numberon the front of this statement. For Hearing or Speech disabilities, use a TRS. Unless your name islisted on this
`statement, your access to information on the account may belimited. You may also mail questions (but not payments) to: P.O. Box 965004, Orlando, FL 32896-5004. Please include
`your account numberon any correspondence you sendto us.
`Payments: Send payments to the addresslisted on the remit portion of this statement or pay online at www.paypal.com
`
`Notice: See below for your Billing Rights and other important information.
`
`
`
`sign is a credit or credit balance unless otherwise indicated. Credits will be applied to
`your previous balance immediately upon receipt, but will not satisfy any required payment
`that may be due.
`|f you believe that we have reported
`Credit Reports And Account Information:
`inaccurate information about you to a consumerreporting agency, please contact us at
`P.O. Box 965005, Orlando, FL 32896-5005.
`In doing so, please identify the inaccurate
`information and tell us why you believe it is incorrect.
`If you have a copy of the credit
`report that includes the inaccurate information, please include a copy of that report. We
`may report information about your account to credit bureaus. Late payments, missed
`payments, or other defaults on your account maybe reflected in your credit report.
`Bankruptcy Notice: |f you file bankruptcy, you must send us notice,
`including account
`number and all information related to the proceeding to the following address: P.O. Box
`965064, Orlando, FL 32896-5064
`Paying Interest:
`Your due dateis at least 25 days after the close of eachbilling cycle. We will not charge
`you any interest on non-promotional transactions if you pay your entire balance by the
`due date each month. We will begin charging interest on promotional purchases on the
`purchase date
`How We Calculate the Balance on Which the Interest is Computed:
`We calculate interest on your account for each billing cycle separately for each balance
`type. A separate average daily balanceis calculated for the following balance types, as
`applicable: standard purchases, cash advances and promotional purchases. To get the
`average daily balance, we take the starting balance each day, including billed interest
`and billed fees, add any new charges and adjustments posted that day and subtract
`any payments or credits (treating any net credit balance as zero). This gives us the
`daily balance. Then, we add up all the daily balancesfor the billing cycle and divide the
`total by the numberof daysin the billing cycle. The result is the average daily balance.
`The average daily balance is referred to as the Balance Subject to Interest Rate on
`your statement.
`Amount to Avoid Standard and DeferredInterest on your next statement:
`(see PAYMENT INFORMATION box on front page).
`This amountincludes:
`Standard Purchases and Cash Advances
`Purchases without any promotional offer and Cash Advances
`Deferred Interest Purchases Expiring This Billing Cycle
`Purchases made with ‘No Payments + No InterestIf paid in full’ and ‘No Interestif paid in
`full’ promotions that are about to expire.
`Easy Payments Purchases Monthly Plan Payments
`Although unrelated to avoiding Standard and Deferred Interest, we include Monthly Plan
`Payments to help you avoid late fees. If you have a Financed Easy Payments Purchase
`balance, you will continue to be assessed interest on the Easy Payments Purchase
`balanceuntil it is paid in full.
`Your Account is owned and serviced by Synchrony Bank.
`
`Purchases, returns, and payments made just prior to billing date may not appear until next month’s statement. When you provide a check as payment, you authorize us either to use
`information from your check to make a one-time electronic fund transfer from your account or to process the payment as a check transaction. When we use information from your check
`to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your
`financial institution. You may choose not to have your checkcollected electronically by sending your check (with the payment stub), in your own envelope — not the enclosed
`window envelope, addressed to: P.O. Box 530993, Atlanta, GA 30353-0993 and not the Payment Address.
`WhatTo Do If You Think You Find A Mistake On Your Statement
`If you think there is an error on your statement, write to us at:
`Synchrony Bank
`P.O. Box 965003
`Orlando, FL 32896-5003
`Or call customer service at 1-844-373-4961
`If you write to us, in your letter, give us the following information:
`+ Account information. Your name and account number.
`+ Dollar amount: The dollar amount of the suspected error.
`« Description of Problem: |f you think there is an error on your bill, describe what you
`believe is wrong and whyyou believeit is a mistake
`You must contact us within 60 days after the error appeared on your statement.
`You must notify us of any potential errors in writing or by calling customer service at
`1-844-373-4961
`While we investigate whether or not there has been an error, the following are true:
`«We cannottry to collect the amount in question or report you as delinquent on
`that amount
`« The charge in question may remain on your statement, and we may continue to charge
`you interest on that amount. But, if we determine that we made a mistake, you will not
`have to pay the amount in question or any interest or other fees related to that amount.
`*While you do not have to pay the amount in question, you are responsible for the
`remainder of your balance.
`«We can apply any unpaid amount against your credit limit.
`Your Rights If You Are Dissatisfied With Your Credit Card Purchases
`If you are dissatisfied with the goods or services that you have purchased with your credit
`card, and you have tried in goodfaith to correct the problem with the merchant, you may
`have the right not to pay the remaining amount due on the purchase
`To usethis right, all of the following must be true:
`1.The purchase must have been made in your home state or within 100 miles of
`your current mailing address, and the purchase price must have been more than
`$50.
`(Note: Neither of these are necessary if your purchase was based on an
`advertisement we mailed to you, or if we own the company that sold you the goods
`or services.)
`2.You must have used your credit card for the purchase. Purchases made with cash
`advances from an ATM or with a check that accesses your credit card account do
`not qualify.
`3.You must not yet have fully paid for the purchase.
`If all of the criteria above are met and you arestill dissatisfied with the purchase, contact
`us in writing at
`Synchrony Bank
`P.O. Box 965003
`Orlando, FL 32896-5003
`Or call customer service at 1-844-373-4961.
`While we investigate, the same rules apply to the disputed amount as discussed above
`After wefinish our investigation, we will tell you our decision. At that point, if we think you
`owe an amount and you do not pay we may report you as delinquent
`information About Payments: You mayat any time pay, in whole or in part, the total
`unpaid balance without any additional charge for prepayment.
`Payments made by mail or made using a third-party bill pay service provider:
`Payments received after 5:00 p.m. (ET) on any day will be credited as of the next day.
`Credit to your Account may be delayed up to five days if payment(a) is not received at
`the Payment Address,(b) is not made in U.S. dollars drawn on a U.S. financial institution
`located in the U.S., (c) is not accompanied by the remittance coupon attached to your
`statement, (d) contains more than one payment or remittance coupon, (e) is not received
`in the remittance envelope provided or(f) includes staples, paperclips, tape, a folded
`check, or correspondence of any type.
`|f you make a payment by phone or online before
`Payments made by phoneor online:
`11:59 p.m. Eastern Time, wewill credit it as of the date the payment is made
`Conditional Payments: All written communications concerning disputed amounts, including
`any check or other payment instrument that: (i) indicates that the payment constitutes
`“paymentin full” or is tendered asfull satisfaction of a disputed amount; or(ii) is tendered
`with other conditions or limitations (“Disputed Payments”), must be mailed or delivered to
`us at P.O. Box 965003, Orlando, FL 32896-5003
`
` Credits To Your Account: An amount shown in parenthesis or preceded by a minus (-)
`
`[WF735246A]
`
`O1DR6128 - 3 - 02/21/19
`
`This is an attemptto collect a debt and any information obtained will be used for that purpose.
`
`*By providing a telephone number on your account, you consent to Synchrony Bank and any other owneror servicer of your account contacting you about your account, including using
`any contact information or cell phone numbers you provide, and you consentto the use of any automatic telephone dialing system and/oranartificial or prerecorded voice when contacting
`you, even If you are charged for the call under your phoneplan.
`
`For changesof address, phone numberand/or email, please check the box and print the changes below. These changeswill be applied to PayPal Credit but not to your PayPal Account.
`
`Street
`Address
`LI
`City, State
`ZIP
`Phone #
`*Business Phone #
`Email
`“Home Phone #
`*Cell # or other phone #
`“Email Address
`we can use to contact you
`
`
`
`**“By providing your email address, you agree to receive email communications about your account and also give permission for us to share your email address with PayPal Credit.
`
`

`

`
`
`
`
`EXHIBIT B
`EXHIBIT B
`
`
`
`
`
`

`

`Statement Closing Date: 07/02/20
`Days in Billing Period: 30
` 3402
`Account Number:
`Customer Name: BRIAN O'CEALLAIGH
`ACCOUNT SUMMARY
`Previous Balance
`- Payments & Credits
`+ Purchases & Adjustments
`+ Fees
`+ INTEREST CHARGES
`= New Balance
`
`Credit Limit
`Available Credit
`
`$2,300.16
`$0.00
`$0.00
`$0.00
`$56.84
`$2,357.00
`
`$1,900.00
`OVERLIMIT
`
`CURRENT ACTIVITY
`
`INTEREST CHARGED
`Tran Date
`Posting Date Description
`07/02/20
`07/02/20
`Interest Charge on Purchases
`07/02/20
`07/02/20
`Interest Charge on Cash Advances
`
`View your account online at paypal.com
`Or call 1-844-377-4136 8 AM ET to 11 PM ET
`Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun
`
`PAYMENT INFORMATION
`New Balance
`Amount Past Due
`Minimum Payment Due
`Payment Due Date
`Amount to avoid Standard and Deferred Interest
`on your next statement:
`See Reverse
`
`$2,357.00
`$347.00
`$411.00
`07/27/20
`
`$2,357.00
`
`Late Payment Warning: If we do not receive your minimum payment
`by 07/27/20, 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 will
`take you longer to pay off your balance. For example:
`spacing
`If you make no more
`charges using this
`account and each
`month you pay:
`
`You will pay off the
`balance shown on this
`statement in about:
`
`And you will end up paying
`an estimated total of:
`
`Only the minimum
`Payment
`
`8 Years
`
`$4,463.00
`
`If you would like information about credit counseling services, call
`1-877-302-8775.
`
`Total Interest
`
`
`
` Amount
`$50.06
`$6.78
`$56.84
`
`
`
`Total Interest Charged in 2020: $299.86
`
`2020 Totals Year-To-Date
`Total Fees Charged in 2020: $114.00
`
`INTEREST DETAILS
`
`INTEREST CHARGE CALCULATION
`Balance Type
`
`Standard Purchases
`Balance Prior To Terms Change
`Balance Prior To Terms Change
`No Interest If Paid In Full
`(v)=Variable Rate
`
`Your Annual Percentage Rate (APR) is the annual interest rate on your account.
`Annual Percentage
`Balance Subject to
` Interest Charged
`Current Balance
`Rate(APR)
`Interest Rate
`23.99% (v)
`$961.87
`19.99%
`$412.90
`19.99%
`$829.65
`23.99% (v)
`$95.74
`
`$980.84
`$419.68
`$843.27
`$113.21
`
`$18.97
`$6.78
`$13.62
`$17.47
`
`NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other important information
`
`
`6128
`
` ABJ
`
`001
`
`7 2
`
`200702 0
`
`E X PAGE 1 of 3
`
`1 0 9283 2100 P9VE O1DR6128
`
`
`
`Make Check Payable to PayPal Credit
`
`Return this portion with your payment.
`Write your account number on your check.
`
`To receive electronic statements or make
`online payments visit paypal.com.
`
`PAYPAL CREDIT/SYNCB
`PO BOX 960006
`ORLANDO, FL 32896-0006
`
`Detach and mail this portion with your check. Do not include any correspondence with your check.
`
`Account Number:
`New Balance:
`Payment Due Date:
`Minimum Payment Due:
`
`Amount Enclosed:
`
` 3402
`
`$2,357.00
`07/27/20
`$411.00
`
`$
`
`BRIAN O'CEALLAIGH
`1363 GROVE ST
`
`SAN FRANCISCO CA 94117-1419
`
`
`
`
`00064000024821 004110000235700 000604419 2144623 40280
`
`

`

`Customer Service: For account information, call the numberon the front of this statement. For Hearing or Speech disabilities, use a TRS. Unless your name islisted on this
`statement, your access to information on the account may belimited. You may also mail questions (but not payments) to: P.O. Box 965004, Orlando, FL 32896-5004. Please include
`your account numberon any correspondence you sendto us.
`Payments: Send payments to the addresslisted on the remit portion of this statement or pay online at www.paypal.com
`
`Notice: See below for your Billing Rights and other important information.
`
`
`
`sign is a credit or credit balance unless otherwise indicated. Credits will be applied to
`your previous balance immediately upon receipt, but will not satisfy any required payment
`that may be due.
`|f you believe that we have reported
`Credit Reports And Account Information:
`inaccurate information about you to a consumerreporting agency, please contact us at
`P.O. Box 965005, Orlando, FL 32896-5005.
`In doing so, please identify the inaccurate
`information and tell us why you believe it is incorrect.
`If you have a copy of the credit
`report that includes the inaccurate information, please include a copy of that report. We
`may report information about your account to credit bureaus. Late payments, missed
`payments, or other defaults on your account maybe reflected in your credit report.
`Bankruptcy Notice: |f you file bankruptcy, you must send us notice,
`including account
`number and all information related to the proceeding to the following address: P.O. Box
`965064, Orlando, FL 32896-5064
`Paying Interest:
`Your due dateis at least 25 days after the close of eachbilling cycle. We will not charge
`you any interest on non-promotional transactions if you pay your entire balance by the
`due date each month. We will begin charging interest on promotional purchases on the
`purchase date
`How We Calculate the Balance on Which the Interest is Computed:
`We calculate interest on your account for each billing cycle separately for each balance
`type. A separate average daily balanceis calculated for the following balance types, as
`applicable: standard purchases, cash advances and promotional purchases. To get the
`average daily balance, we take the starting balance each day, including billed interest
`and billed fees, add any new charges and adjustments posted that day and subtract
`any payments or credits (treating any net credit balance as zero). This gives us the
`daily balance. Then, we add up all the daily balancesfor the billing cycle and divide the
`total by the numberof daysin the billing cycle. The result is the average daily balance.
`The average daily balance is referred to as the Balance Subject to Interest Rate on
`your statement.
`Amount to Avoid Standard and DeferredInterest on your next statement:
`(see PAYMENT INFORMATION box on front page).
`This amountincludes:
`Standard Purchases and Cash Advances
`Purchases without any promotional offer and Cash Advances
`Deferred Interest Purchases Expiring This Billing Cycle
`Purchases made with ‘No Payments + No InterestIf paid in full’ and ‘No Interestif paid in
`full’ promotions that are about to expire.
`Easy Payments Purchases Monthly Plan Payments
`Although unrelated to avoiding Standard and Deferred Interest, we include Monthly Plan
`Payments to help you avoid late fees. If you have a Financed Easy Payments Purchase
`balance, you will continue to be assessed interest on the Easy Payments Purchase
`balanceuntil it is paid in full.
`Your Account is owned and serviced by Synchrony Bank.
`
`Purchases, returns, and payments made just prior to billing date may not appear until next month’s statement. When you provide a check as payment, you authorize us either to use
`information from your check to make a one-time electronic fund transfer from your account or to process the payment as a check transaction. When we use information from your check
`to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your
`financial institution. You may choose not to have your checkcollected electronically by sending your check (with the payment stub), in your own envelope — not the enclosed
`window envelope, addressed to: P.O. Box 530993, Atlanta, GA 30353-0993 and not the Payment Address.
`WhatTo Do If You Think You Find A Mistake On Your Statement
`If you think there is an error on your statement, write to us at:
`Synchrony Bank
`P.O. Box 965003
`Orlando, FL 32896-5003
`Or call customer service at 1-844-373-4961
`If you write to us, in your letter, give us the following information:
`+ Account information. Your name and account number.
`+ Dollar amount: The dollar amount of the suspected error.
`« Description of Problem: |f you think there is an error on your bill, describe what you
`believe is wrong and whyyou believeit is a mistake
`You must contact us within 60 days after the error appeared on your statement.
`You must notify us of any potential errors in writing or by calling customer service at
`1-844-373-4961
`While we investigate whether or not there has been an error, the following are true:
`«We cannottry to collect the amount in question or report you as delinquent on
`that amount
`« The charge in question may remain on your statement, and we may continue to charge
`you interest on that amount. But, if we determine that we made a mistake, you will not
`have to pay the amount in question or any interest or other fees related to that amount.
`*While you do not have to pay the amount in question, you are responsible for the
`remainder of your balance.
`«We can apply any unpaid amount against your credit limit.
`Your Rights If You Are Dissatisfied With Your Credit Card Purchases
`If you are dissatisfied with the goods or services that you have purchased with your credit
`card, and you have tried in goodfaith to correct the problem with the merchant, you may
`have the right not to pay the remaining amount due on the purchase
`To usethis right, all of the following must be true:
`1.The purchase must have been made in your home state or within 100 miles of
`your current mailing address, and the purchase price must have been more than
`$50.
`(Note: Neither of these are necessary if your purchase was based on an
`advertisement we mailed to you, or if we own the company that sold you the goods
`or services.)
`2.You must have used