IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
DALE WELLS, )
8717 Ridge Road, )
Ellicott City, Maryland 21043, )
)
SHARON GOLDENBERG, ) Civil No. __________
1760 Park Road, N.W., )
Washington, D.C. 20010, )
)
JOHN DOVEL, )
217 West Cameron Street )
Falls Church, VA 22046 )
)
on behalf of cardholders )
and former cardholders similarly situated, )
)
vs. )
)
CHEVY CHASE BANK, F.S.B., )
A Federal Savings Bank. )
7926 Jones Branch Road, )
McLean, Virginia 22101, )
)
FIRST USA BANK, N.A. )
A National Bank. )
201 North Walnut Street, )
Wilmington, DE 19801, )
)
Defendants. )
__________________________________________)
FIRST AMENDED CLASS ACTION COMPLAINT AND JURY DEMAND
Named Plaintiffs Dale Wells, Sharon Goldenberg, and John Dovel, through their
attorneys, Trial Lawyers for Public Justice, P.C., make this their complaint against defendants
Chevy Chase Bank, F.S.B. and First USA Bank, N.A.
THE PARTIES
1. Named Plaintiff Dale Wells is an individual who resides at 8717 Ridge Road,
Ellicott City, Maryland 21043.
2. Named Plaintiff Sharon Goldenberg is an individual who resides at 1760 Park
SNIPPETS:
IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
FIRST AMENDED CLASS ACTION COMPLAINT AND JURY DEMAND
Named Plaintiffs Dale Wells, Sharon Goldenberg, and John Dovel, through their
attorneys, Trial Lawyers for Public Justice, P.C., make this their complaint against
Named Plaintiff Dale Wells is an individual who resides at 8717 Ridge Road,
Named Plaintiff Sharon Goldenberg is an individual who resides at 1760 Park
Named Plaintiff John Dovel is an individual who resides at 217 West
Cameron Street, Falls Church, Virginia, 22046.
Defendant Chevy Chase Bank, F.S.B. is a federally regulated
savings association with its home office, as that term is defined by Office of Thrift
regulations, 12 C.F.R. § 545.91, currently located at 7926 Jones Branch Road, McLean,
Its Credit Card Division is located in Frederick,
Rules and Regulations and Notice of Billing Rights" (hereafter "Maryland Cardholder Rules")
The Maryland Cardholder Rules provided that no "finance charge" for purchases
APR charged on both balances for purchases and cash advances.
to pre-existing balances unless the cardholder agreement authorized that retroactive
The Maryland Cardholder Rules authorized the application of new, higher APRs
required Chevy Chase to notify cardholders of amendments to the cardholder
periodic rate to calculate finance charges, Chevy Chase would multiply the average daily
purchase balance by a "daily periodic rate."
Chevy Chase began charging its cardholders $20 late fees and $20 overlimit fees.
He used his Visa in accordance with the terms and conditions set forth in the Maryland
THE TERMS AND CONDITIONS OF YOUR CREDIT CARD ACCOUNT WILL BE SUBJECT TO VIRGINIA LAW AND
Chevy Chase agreed that if it amended its Maryland Cardholder Agreement,
January 16, 1996, it failed to provide the contractually required notice under Subtitle 9,
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