HSBC CARD SERVICES, INC. -- CLASS ACTION COMPLAINT

IN THE UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

CHASTITY BRADLEY, individually and
on behalf of all others
similarly situated,



CIVIL ACTION

CASE NO.

HSBC CARD SERVICES, INC.

CLASS ACTION COMPLAINT

Plaintiff, Chastity Bradley, individually and on behalf of all others similarly situated,

allege as and for her Class Action Complaint against Defendant, HSBC Card Services, Inc.

(“HSBC” or “Defendant”), upon personal knowledge as to herself and as to all other matters

upon information and belief, based upon, inter alia, the investigation made by her attorneys, as

follows:


PRELIMINARY STATEMENT

This action is instituted in accordance with and to remedy Defendant’s fraudulent

business practices and mass breach of contracts. Plaintiff brings this action both individually on

her own behalf and as a class action on behalf of all other persons similarly situated, to recover

damages for her and the class and to enjoin Defendant’s unlawful conduct as it affects all other

consumers residing within the United States.

This action seeks redress for the illegal practices of Defendant, concerning the collection

of past due credit debt. Defendant has entered into settlement agreements with law firms and

Debt Settlement Companies, including the law firm that represented Plaintiff. Defendant accepts

all but the remaining few payments from the consumer directly or indirectly through the Debt

Settlement Company or law firm and than unilaterally and without cause refuses to accept the

remaining payment and instead deems the settlement null and void.

Defendant’s mistreatment of Plaintiff and the Class was in fact indiscriminate, occurring

in the regular course of Defendant’s debt collection attempts whereby Plaintiff was treated in the

same general manner as it treats other consumers who are the objects of its collection efforts.

Plaintiff therefore seeks hereby to recover actual, statutory, treble, and punitive damages

on behalf of herself individually, as well as declaratory and equitable relief on behalf of the class

which she seeks to represent, together with reasonable attorneys' fees and costs.



JURISDICTION

1. This Court has subject matter jurisdiction of the claims asserted herein pursuant to

28 U.S.C.§§ 1331 and 1332(d)(2)(A) in that the amount in controversy exceeds the sum or value

of $1,000,000.00, exclusive of interest and costs, and is a class action in which members of the

putative plaintiff class are citizens of States different from Defendant.

2. Venue is proper pursuant to 28 U.S.C.§1391. Defendant is subject to personal

jurisdiction in the District of New Jersey.



PARTIES

2. Plaintiff, Chastity Bradley, is a natural person who resides in Somerville, New

Jersey.

3. Defendant, HSBC Card Services, Inc., is the US consumer credit card segment of

the larger HSBC Holdings. One of the largest credit card servicers in the country, HSBC Card

Services offers private label and HSBC Bank-branded credit accounts, such as Visa, MasterCard,

and American Express with a variety of annual percentage rates and rewards programs. Its

Orchard Bank unit issues cards to consumers looking to establish or re-establish their credit. Its

cards are issued by HSBC Bank USA or its HSBC Bank Nevada affiliate. Defendant operates

from several primary locations, one of which is located at 1301 Tower Road, Schaumburg, Il

60173.



FACTUAL ALLEGATIONS

4. On or about January 22, 2010, Plaintiff with the assistance of her personal legal

counsel entered into a settlement agreement with the Defendant on a past due account. See a

copy of the letter appended hereto and marked “EXHIBIT A”.

5. Defendant, as shown in “EXHIBIT A” agreed to accept the Plaintiff’s proposal

of $481.00 as full settlement on the aforementioned account.

6. Defendant promised that upon all of the funds clearing and the proceeds applied

to the Plaintiff’s account that said account would be settled and closed.

7. Plaintiff issued all required payments as instructed in “EXHIBIT A” in a timely

fashion.

8. Defendant accepted and deposited all payments with the exception of the final

installment paid out on the agreed settlement.

9. On or about August 23, 2010, Plaintiff’s legal counsel contacted the Defendant.

See a copy of the letter appended hereto and marked “EXHIBIT B”.

10. “EXHIBIT B”, inquired as to the reason that the Plaintiff’s final payment was

rejected when all previous payments had been satisfied in a timely fashion and were not returned.

11. Defendant returned the final payment without explanation and insisted upon

collection of the full balance due in total disregard of the settlement agreement.

12. Defendant lured in Plaintiff and all those similarly situated with a discounted

settlement amount; only to accept all but the final payment and proceed to declare the settlement

void.



CLASS ACTION

13. This action is maintained as a class action on behalf of the following described

class: all consumers residing in the United States who entered into a settlement agreement with

the Defendant that was not honored and have been the subject to the fraudulent practices and

breach of contract at the hands of the Defendant.

14. This action is appropriately maintained as a class action as the class is so

numerous that joinder of all members is impracticable, there are questions of law or fact common

to the class, the claims of the representative party are typical of the claims of the class, and the

representative party will fairly and adequately protect the interests of the class; in addition,

Defendants have acted or refused to act on grounds generally applicable to the class, thereby

making appropriate final injunctive relief or corresponding declaratory relief with respect to the

class as a whole.

15. Unless Defendant is enjoined and restrained from continuing the foregoing illegal

practices, Plaintiff and the class whom she represents will suffer substantial and irreparable

injury for which they have no adequate remedy at law.

What's the status now?

You may find this very helpful.

HAVE SHAREHOLDERS BEEN CHEATED ?
PLEASE LETS CHECK.
Dear Shareholder
We ask should you be concerned about the behaviour of our Chairman & Board of Directors? Look at complaints in India then look at USA.
The Chairman states “maintaining our reputation and our integrity”
“Everything we do is governed by the imperative of upholding HSBC’s corporate reputation and character at the highest level”.

Ask our CUSTOMERS IN INDIA about HSBC'S REPUTATION, INTEGRITY and CHARACTER and what HSBC has done and is doing to them.
452,130 REGISTERED COMPLAINTS in INDIA between 2006-2010

The State Consumer Disputes Redressal Commission Castigated the Hongkong & Shanghai Banking Corporation Ltd (HSBC Bank) due to the unlawful functioning of the BANK.
The Judge who wrote the judgment, clearly held that there is deficiency in the service rendered by HSBC which 'had acted against the guidelines issued by the RBI and Banking Codes Standards board of India in regard to the code of bank's commitment to customers'. Should Shareholders be concerned?
Our Chairman states “we deeply regret that a number of weaknesses in regulatory compliance were highlighted in 2010”Weaknesses really?

Information supplied by HSBC to a sitting MP, we say the INFORMATION was FALSE and MISLEADING (we refer to the Oxford Dictionary for the meanings). The Chairman says it was an error. We ask if this is another weakness Chairman.

These are some of the ALLEGATIONS BEING MADE about HSBC’s Collection Department by CUSTOMERS of HSBC INDIA. They believe they have been HARASSMENT, VERBAL THREATS made, and the use of INTIMIDATION.

Will the Chairman of the future be stating “we deeply regret a number of weaknesses in regulatory compliance” when referring to HSBC’s behaviour in India?

Should Shareholders be concerned about what is going on in India with HSBC? HSBC asked to pay Rs 20 lakh for wrongly blacklisting customer - The Times of India

HSBC credit card department Complaints - Mental Harrassment to pay the amount for a credit card belongs to another person
Unauthorized use of my HSBC credit card

Indian Consumer Complaints Forum | hsbc bank



HELP STOP ABUSE OF CUSTOMER’S in India. PLEASE HELP
Kind regards Michael E-mail: ckmdm@aol.com Mobile: 07834763544

[jamunadas1]

HSBC bank is one of important bank in our world domination. Their activity is widening day by day. They give us opportunity to take a credit cards and and do fast money transaction in their bank.

Take a look at the front page of the Citywire Money website - http://citywire.co.uk/money/exclusiv...test-news-list

I once again attended AGM on the 27 of May 2011 where again I raised my concern about HSBC India and its behaviour towards their customers.

You may first like to go to HSBC AGM, go to questions and answers 40:11 min's in then go to Resolutions 19:02 min's in. As you will see Mr Flint could not get his facts right or was he misleading shareholders or was this just another weakness by the Chairman. The information the Chairman gave about customers complaints in India was not totally true.

http://www.thomson-webcast.net


The Chairman stated that is was a invidious irritation to customers when they were registered on CIBIL.

It is not an invidious irritation, it prevents a person from borrowing from any other lender, it has a very serious impact on that person and their lives.

So did the Chairman trivialise their complaints or was he trying to belittle the complainants in India?

Is this Chairman just ignorant to what it means when a person is registered on CIBIL or did the Chairman deliberately give false and misleading information to shareholders and the AGM. ? YOU DECIDE