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US District Judge Vitalano

US Magistrate Judge Bloom


Martin, Jessica (Plaintiff)
150 74th Street, Apt 2H
Brooklyn, NY 11209
VS
American Education Services (Defendant)
Adam Michaels (Attorney)
The New York Times Building
37th Floor
620 Eighth A venue
New York, NY 10018-1405
Settlement Conference Considerations
ORIGINAL
1 R 1 ~ ~ ~ n 1 ~ [ O
OCT 1 1 2011
PRO SE OFFICE
Please consider and review attached documents which are as followed: Credit Report,
letters from American Education Services regarding deferment and forbearance periods,
Letter of therapist visits. Plaintiff, Jessica Martin, Pro Se, did not include all of the
documentation that she has regarding her case against American Education Services since
it would be a repeat of the documentation that she already submitted to the court and
defendant via Original Complaint, Amended Complaint, and Request for Summary
Judgment. For this reason, Plaintiff is submitting this documentation to highlight facts
regarding her complaint and the main reason for her suit against the defendant, American
Education Servicing.
1. Please refer to Plaintiff s recent attached credit reports from Transunion and
Equifax. From 09/2010 to 09/2009, American Education Services reported
Plaintiff as being 120-149 days to 180 or More Days Past Due to the Credit
Reporting Agencies. However on 8/27/2009, Plaintiff faxed and mailed the
required American Education Services Documentation that she was enrolled in
school full-time. Adelphi University also notified American Education Services
electronically, via National Clearing House, on 9/23/2009 of Plaintiffs full-time
enrollment status. Plaintiff was told by Customer Service Representative via
phone that the notification of full-time enrollment was received and she was in In-
school deferment; however not until 10/2010 did American Education Services
update my American Education Services Account as deferred from 05/07/2009 to
08/3112010; they subsequently sent Plaintiff a letter stating "changed
forbearance status." Even though Plaintiff was not in "forbearance" during that
period; she was in "In school deferment" since she was enrolled full-time at
Adelphi University from 09/2009 to present and enrolled at Raritan Valley
Community College from OS/2009 to 08/2009. Currently Plaintiff is correctly in
Full-time "In School deferment" status till 05/31/2012. Jessica's complaint is that
American Education Services recognizes/corrects their administrative errors at a
later time after plaintiff s initial submissions of deferment/forbearance as
"
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 1 of 15 PageID #: 173
evidenced by notices that state "changed forbearance status, changed
deferment status, and courtesy forbearance"; however they fail to correct the
errors on her credit reports (Experian, Equifax, and Transunion), which ruined
Jessica's credit history. Plaintiff attests that is the only account on her credit
report which prohibits her from acquiring some of the things that are vital to her
quality of life: housing, transportation, and education.
a. 01120/2009 to 05/04/2009, Plaintiff was enrolled at Raritan Valley
Community College and received in school deferment and it was
acknowledge by customer service representatives. Plaintiff applied for in
school deferment prior to the start of the semester in the month of
December 2008. In the month of January, Raritan Valley Community
College, notified American Education Services electronically via National
Clearing House of Plaintiff's enrollment. Her enrollment was
acknowledge by American Education Services for the period of the Spring
semester of 0112012009 to 05/0412009; however Plaintiff's credit report
reflects her being delinquent from 150-179 days past due 180 or more
days past due during that period.
b. 01107/2009 to 01/19/2009, American Education Services placed on
Plaintiff's account a "courtesy forbearance"; however Plaintiff was in
economic hardship forbearance during that time and also applied for and
was accepted for in school forbearance during that time period.
c. 01/0112008 to 12/30/2008 and 0110112008 to 12/30/2008, 12/0112006 to
11/30/2007, Plaintiff applied for Economic Hardship Forbearance and
confirmed with Customer Service Representatives of receipt of application
and subsequent acceptance. Since 09/2009 when following up with
customer services representatives they made Plaintiff aware that she failed
to submit the proper documentation or properly filled documentation that
was the reason as to the failure of her request for forbearance to be
submitted on time causing delinquencies to appear on her credit report.
However plaintiff attests that she indeed submitted the correct paper via
fax and by mail and it was acknowledge and accepted by the defendant
despite additional applications or stated "correct application." The plaintiff
reasons that her request for Economic Hardship Forbearance was
eventually applied to her account and believes that it was negligence and
administrative error that caused American Education Services to report her
account delinquent since 04/2008 to 09/2010.
d. Plaintiff asserts that she has diligently applied and received the designated
forbearance and deferment; however American Education Services
reported her information incorrectly to the credit bureaus. Plaintiff
believes that the defendant did indeed inflict emotional distress to the
plaintiff by repeatedly ignoring each request directly and indirectly (via
credit reporting agencies) for an adequate investigation and removal of
credit reporting errors. The Plaintiff asks the court to not focus on the
length of economic hardship forbearance and deferment since Plaintiff has
every intention to payoff student loan debt prior to 09/2009 discovery of
errors and each application of forbearance and deferment; however
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 2 of 15 PageID #: 174
through various reasons: unfortunate family tragedy and economic
circumstances she decided to invest her money into other areas of
obligations versus My Rich Uncle Student Loan at the time. The Plaintiff
asserts that she had and still does have every intention to payoff that
student loan.
e. Plaintiff did not seek to file suit against My Rich Uncle since defendant,
American Education Services, is servicing her loans and My Rich Uncle
Student Loan Company is defunct.
2. Punitive Damages: Plaintiff has sought therapy/counseling over the matter against
the Defendant and burden of apartment application rejections, not accepting
admission into her first school of choice, deferment of career pursuits, failed
attempts at correcting credit reporting errors, working full-time and going to
school full-time, and other matters which were named in original and amended
complaint. The Defendants action has caused insurmountable emotional and
financial distress to the Plaintiff. Therefore the plaintiff is seeking and requesting
punitive and statutory damages.
a. My original suit was for $878,000.00, $28,000 of which consists of $1 ,000
for each credit reporting error. $450,000 of which are statutory damages.
$400,000 of which are punitive damages.
b. However, on October 1 st, Plaintiff notified American Education Services
via Attorney Adam Michaels that she is willing to settle for the following:
Removal of credit reporting errors, all of the 28 late payment status on my account within
60 days. Fine: $28,000, $1,000 for every violation. Punitive and Statutory Damages of
$450,000. Total of $478,000 versus the 878,000, I have filed suit for.
c. However, Plaintiff would like to request a change in settlement proposal.
She would like the removal of credit reporting errors to occur within 30
days instead of 60 days.
3. James Jarecki esq. in previous correspondence with Plaintiff via email made
Jessica aware that with any settlement between the defendant and herself that
attorney fees will be deducted from any settlement agreement that is reached;
however Plaintiff respectfully requests the US District Judge VitalanolUS
Madgistrate Judge Bloom opinion in regard to that matter since as a Pro Se
litigant, it has taken her a lot of time, research, and effort in conjunction with
family, work, and academic obligations to file suit against American Education
Services. She does not believe that attorney fees should be deducted from any
settlement agreement and should be absorbed by the defendant. Plaintiff has done
her due diligence and is seeking quick resolution of this issue that has persisted
for approximately 2 years.
4. Plaintiff believes her settlement agreement is reasonable considering all the facts
and damages inflicted on plaintiff and believes that plaintiff will win case in
audience of jury for full or most of the $878,000 requested in suit; however she is
willing to settle for $478,000/removal of all credit reporting errors (i.e., three
credit reporting agencies notified within 30 days).
5. Plaintiff respectfully requests that the defendant, American Education Services
analyze each of their clients' accounts. Plaintiff believes that the defendant's
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 3 of 15 PageID #: 175
negligence and lack of regard for their clients' credit records and reputation
causes irreparable harm to their clients.
a. In the unfortunate downturn of the economy these actions are very
harmful to the livelihood of many Americans who are new graduates,
continuing their education, or attempting to improve their income potential
by advancing or changing their careers. "Mismanagement of paperwork"
as defendant's attorney Adam Michael's stated, can really devastate the
lives of their clients; such as the harm that was inflicted on the Plaintiff.
The plaintiff suggests that American Education Services develops a Credit
Reporting Department within the company or establish some form of
project that looks over the accounts of their clients and make certain that
there are no discrepancies or "mismanagement of paperwork" and thereby
seek to correct it. As a student loan servicing company that is providing
loans to students to help them reach their goals; it is feasible and
obligatory to seek to help clients by making certain that the information
reflected on their American Education Services account is equivalent to
the information that is reported to the Credit Reporting Agencies;
especially if that information has been changed. Plaintiff believes that
American Education Services has done a poor job servicing the student
loan accounts of behalf of their clients.
x __ __ ____ ~ ____________ _
artin
150 Street, Apt 2H
Brooklyn, NY 11209
cc. American Education Services
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 4 of 15 PageID #: 176
File Number:
Page:
Date Issued:
-Begin Credit Report-
242221272
1 of 1
09/29/2011 TransUnion.
on Your report begins with'MED1'. It ml:!dicallnformatl?r .and the data fol\?wing 'MEDt'!s not displayed to anyone but
perml.tted by.law; .' ' ,"" '. 'i:
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genera Ily. lJe repPJted for 7. years
itstdellinqueljcy. dePefitdi,nlg I?n youi-state.of "ii' . ",. has ,been printed or is
ygu\lm:l,erstand V9urreport:They .
AES #5516551110PAO****
POB 2461
HARRISBURG, PA 17102-2461
(800) 233-0557
Balance:
Date Verified:
High Balance:
Collateral:
Terms:
$38,376
09/2011
$28,125
DEFERRED TO 06012012
149 MONTHLY
- End of investigation results -
Pay Status: CURRENT; PAID OR PAYING AS
AGREED
Account Type: INSTALLMENT ACCOUNT
Responsibility: INDIVIDUAL ACCOUNT
Date Open: 11/2005
To view a free copy of your full, updated credit file, go to our website http://disclosure.transunion.com
-End of Credit Report-
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 5 of 15 PageID #: 177
EQ...f.lIFAX
CREDIT FILE: September 21, 2011
Confirmation # 1232015967
Dear Jessica Martin:
Your request for Equifax to reinvestigate certain items of your credit file is now complete.
Below are your results and a report of your credit file revised, as applicable, as a result of the reinvestigation. If you
have additional questions regarding the reinvestigated items, please contact the source of that information directly.
You may also contact Equifax regarding the specific information contained within this letter or report within the next
60 days by visiting us at www.investigate.equifax.com or by calling a Customer Representative at (888) 588-0688
from 9:00am to 5:00pm Monday-Friday in your time zone.
Thank you for giving Equifax the opportunity to serve you.
I The Results Of Our Reinvestigation
Credit Account Information
(For your security, the last 4 digits of account number(s) have been replaced by *)
(This section includes otJen and closed accounts reported bv credit grantors)
Account History
1 : 30-59 Days Past Due 5 : 150-179 Days Past Due J : Voluntary Surrender
Status Code
2 : 60-89 Days Past Due 6 : 180 or More Days Past Due K : Repossession
3: 90-119 Days Past Due
G : Collection Account
L : Charge Off
Descriptions
4 : 120-149 Days Past Due
H : Foreclosure
>>> We have researched the credit account. Account # - 5516551110PAO* The results are: The status of this
account has been updated. The prior paying history on this account has been updated. Additional information has
been provided from the original source regarding this item. If you have additional questions about this item please
contact: AeslMru Funding Spv Inc., 1200 N 7th St, Harrisburg PA 17102-1419 Phone: (800) 233-0557
AeS/Mru Funding Spv Inc.
1200 N 7th St Harrisburg PA 17102-1419: (800) 233-0557
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Date Opened High Credn Credit Limn Terms Duration Terms Frequency Months Revd Activity Designator Creditor Classification
Items As of Balance
Date Reported Amount
09/2011 $38,376
Amount
Past Due
$0
11/2005 $28,125 $28,125
Date of Actual
last Paymnt Paymnt Amount
Scheduled
Paymnt Amount
04/2006 $0 $0
Date of 1st
Delinquency
Deferred
Date of
last Activijy
07/2008
50
Date Maj. Charge Off
Del. 1 st Rptd Amount
$0
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Start Date Amount
06/2012 $0
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- Pays As Agreed; Type of Account - Installment; Type of Loan - Education Loan; Whose Account - Individual Account; ADDITIONAL INFORMATION - Consumer Disputes
ThiS Account Information; Student Loan - Payment Deferred;
Account History 09/2010 08/2010 07/2010 06/2010 05/2010 04/2010 03/2010 02/2010 01/2010 12/2009 11/2009 10/2009 09/2009 08/2009 07/2009 05/2009 0412009 03/2009 0212009 01/2009 1212008
with Status Codes 6 6 6 6 6 6 6 6 6 6 6 5 4 3 2 1 6 6 6 5 4
11/2008 10/2008 09/2008 0412008
3 2 1 2
( C0.ntinued On Next Page) Page 1 of 2
1232015967APP-001040693- 787- 8848 - S
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 6 of 15 PageID #: 178
.' Case 1 D.Q.cument 11
Case 1:11-cv-03319-ENV-LB Document 1 Filed 07/07/11
'-"
7 44 PagelD # 71
Page 6 of 44 PagelD #: 6
1M
JUNE Z7 I 2011
IBWNDHKB
IB438 0158 8306 28L41
JESSICA MARTIN
150 74TH ST APT ZH
BROOKLYN NV 11209-2239
DEAR CUSTOMER:

American Education Services
P.O. Box 2461 Harrisburg. PA 17105-2461
Toll-free 1-800-233-0557' TOO 717-720-2354
Fax 717-720-39\6' IntemationaI717.720-3JOO
www.aesSuccess.org
ACCT NUMBER: 5516551110
This letter is in response to your recent inquiry regarding the
deferments and/or forbearances on your educational loan account. The
effective dates of the deferments and forbearances that are currently
applied to the loans listed in the LOAN INFORMATION section are listed
below. We trust this will be of assistance.
DEFERMENT/FORBEARANCE TVPE
Economic Hardship Forbearance
Economic Hardship Forbearance
Courtesy Forbearance
School Deferment
Courtesy Forbearance
School Deferment
BEGIN PATE
12/01/06
01/01/08
01/07/09
01/20/09
05/07/09
09/01/10
END PATE
11/30/07
12/30/08
01/19/09
05/04/09
08/31/10
05/31/12
If you have any questions, you may contact us at the telephone number or
address shown above. loan Counselors are available to discuss your
account Monday through FridaY, from 7:30 a.m. to 9 P , ET.
Customer Service Department
American Education Services
PH13163sPS060HIST
5516551110 5516551110 MR
00008111790001402
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 7 of 15 PageID #: 179
1: 11 9 of 44 D #:
CaSe 1:11-cv-03319-ENV-LB Document 1 Filed 07/07/11 Page 8 of 44 Pagel 0 #: 8
"-'"
AMERICAN EDUCATION SERVICES
DEFERMENT/FORBEARANCE LOAN DECLARATION
AceT II S5 1655 1110 NAME I JESSICA MARTIN
REQUESTED TYPE BEGIN DATE END DATE
------------- -------------------- ---------. --------
DEFERMENT FULL TIME SCHOOL 09/01/10 05/31/11
lST DISB
LOAN PGM CURRENT OWNER DATE
CURRENT
PRINCIPAL
DATE I 10119/10
REPAYMENT
START DATE
HRUUGD MRU 11/03/05 .37,458.72 11/02/06
ACTION TYPE
GRANTED DEFERMENT FULL TIME SCHOOL
CHANGED'FORBEARANCE ADNlttISTRAflVe
GRACE END
BEGIN DATE END1DATE DATE
09/01/10 05/31/11
OS/tl7/'9'-----{)8/-3-1/10
-
-----'. ---
- END OF REPORT -
- .-' '--' .....
-..
-'--,
..
'.
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 8 of 15 PageID #: 180
8 Document 11 44 PagelD #: 75
Case 1:11-cv-03319-ENV-lB Document 1 Filed 07/07/11 Page 10 of 44 PagelD #: 10
. '.
'-' ......,J
AMERICAN EDUCATION SERVICES
DEFERMENT/FORBEARANCE LOAN DECLARATION
ACCT 'I SS 1655 1110 NAME I JESSICA MARTIN
REQUESTED TYPE BEGIN DATE END DATE
.. ---.-.---.. ---.---------------- -.-.------ --------
DEFERMENT FUll TIME SCHOOL 09101/10 05/31/12
DAN PGM CURRENT OWNER
lRUUGD MRU
1ST DIS8
DATE
11/03/05
CURRENT
PRINCIPAL
'37.765.57
DATEI 03/04/11
REPAYMENT
START DATE
ACTION
TYPE
11/02/06
GRACE END
BEGIN DATE END ~ T DATE
---------
FuLl-riMe-scHOOL---- -o;ioiiio
CHANGED DEFERMENT
05/31/12
- END OF REPORT -
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 9 of 15 PageID #: 181
-"

1 17
Secure mail from AES/PHEAA
Secure Mailbox
VlfW MESSAGE
su eJECT: RE: <lnd Defe rment Periods [nO II 062300HKSo 1 OZ45494 7 3 J
fROM: aescs@aessuccess.org
TO: marljes20Q4Js@yahoo.con1
SENT: Fr; 24 Jun 2011 15: 17:05 EDT
EXPIRES: Tue 23 Aug 2011 15: 17:05 EDT
Reply Reply to All
Dear Jessica Martin,
? HELl>
Thank you for contacting American Education Services (AES), Your loan was in the In-School Status until May I,
2006 and the grace period was over November 1, 2006_ This status started on November 3, 2005, the dale the
loan was disbursed.
An Economic Hardship Forbearance was applied to your account from December I, 2006 through May 31, 2007.
An Economic Hardship Forbearance was applied to your account from June 1, 2007 through November 30, 2007.
An Economic Hardship Forbearance was applied to your account from January J, 2008 through June 30,2008.
An E.conomic Hard.<;hip Forbearance was applied to your account from July 1, :z008 through December 30, 2008.
An Administrative Forbearance was applied to your account from January 7.2009 through January 19. 2009.
An In-School Deferment was applied to your account from January 20. 2009 through May 4, 2009.
An Administrative Forbearance was applied to your account from May 7, :1.009 through August 31,2010.
An In-School Deferment was applied to your account from September 1, 2010 through May 31,2012.
During a deferment and forbearance you are responsible for the accruing interest on your loans. You may choose
to pay the accruing interest while your payments are deferred. You may view the amount of outstanding interest
on our website. Once you have accessed your account online, select "View Loan Details" in the navigation menu
on the left side of the SCreen. The amount of interest outstanding on your account can be viewed under the
current principal balance. By clicking "View Details" for a loan you can view the amount of interest outstanding
on that loan. Although you are not obligated to satisfY the accruing intcrest while your payments are deferred, it i.s
to your benefit. Any unpaid accrued interest will be capitalized (added to the principal balance) once the account
enters repayment.
If you require further assistance, please visit OUf website at www_aessuccess.org. From the homepage, you may
click on th" ?Contaet Us? link, which will provide you with useful information such as our Cl.C>tomer Service
Department hours of operation and telephone number, and will allow you to submit inquiries via a secure c-rnail.
If you have an online account, you ",ill find additional services available and may obtain account specific
information_
Sincerely,
Chasity
American Education Services
https:llsecuremall.aessuccess.orgfmessengcrldef/twpurllNonUscrPurl.do?x=d-37280445-t... 8/22/2011
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 10 of 15 PageID #: 182
ADELPHI UNIVERSITY
Garden City New York 11530
Dear Jessica:
STUDENT COUNSELING CENTER
UNIVERSITY CENTER - ROOM 31.
tel. (516) 877-3646
fax (516) 877-3139
Enclosed are two copies of the letter you requested, noting all of the dates of your attendance at
the Student Counseling Center. Per our conversation on Wednesday, September 28, 2011, I am
sending these letters to your home address. Thank you.
~
~ -------
Bernadine Y. Waller, MA, MHC
Counselor
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 11 of 15 PageID #: 183
ADELPHI UNIVERSITY
Garden City New York 11530
September 30, 2011
To Whom It May Concern:
STUDENT COUNSELING CENTER
UNIVERSITY CENTER - ROOM S I.
leI. (516) 877-3646
fax (516) 877-3139
This is to inform you that Jessica Martin was seen at the Student Counseling Center on the
following dates:
1/15/10
7/6/10
7/13/10
3/9/11
6/30/11
8/3/11
8/10/11
8/17/11
8/31/11
9/14/11
~ ~ ~
~ c . ? ~
Bernadme Y_ Waller, MA, MHC
Counselor
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 12 of 15 PageID #: 184
Gmail - Jessica Martin v. American Education Services
Page 1 of 1
Miss Martin <jmartin11209@gmail.com>
Jessica Martin v. American Education Services
Jessica Martin <jmartin11209@gmail.com>
To: James J Jarecki <jjarecki@pheaa.org>
Cc: michaelsa@pepperlaw.com
Hello James and Adam,
Thu, Sep 29, 2011 at 1:19 PM
Did you receive my notice for promissory note to be sent to me? My main objective is for the credit reporting
errors and the reported default to be removed from my credit report. If you would like us to discuss settling
this matter we can go ahead and do so or having a settlement meeting with the Magistrate Judge Bloom or
District Judge Vitaliano.
Best Regards,
Jessica Martin
732-742-0209 ,
https:llmail.google.com/maill?ui=2&ik=0977c6706f&vicw=pt&scarch=sent&msg=132b6... 10/6/2011
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 13 of 15 PageID #: 185
Gmail - Jessica Martin v. American Education Services
Page 1 of 1
Miss Martin <jmartin11209@gmail.com>
'<'i,
Jessica Martin v. American Education Services
Michaels, Adam <michaela@pepperlaw.com> Fri, Sep 30, 2011 at 11 :12 AM
To: "jmartin11209@gmail.com" <jmartin11209@gmail.com>
Ms. Martin -
As you are aware, we are legal counsel for the Pennsylvania Higher Education Assistance Agency d/b/a
American Education Services (AES/PHEAA). Because AES/PHEAA is now represented by counsel, please
direct all communications to me and do not contact any AES/PHEAA employee.
It is my understanding that Mr. Jarecki from AES/PHEAA attempted to resolve this dispute before we were
hired, that you insisted "not until AES/PHEAA filed an answer," and that Mr. Jarecki warned that once counsel
was hired AES/PHEAA would have very little interest in discussing settlement. As was made clear in my
letter to the Court, AES/PHEAA will be filing a motion to dismiss shortly.
That being said, if there is a proposal you wish to make, I am willing to take that back to my client for
consideration.
Adam B. Michaels
Pepper Hamilton LLP
The New York Times Building
620 Eighth Avenue
New York, NY 10018
Tel. 212.808.2746
Fax 866.422.0197
From: Jessica Martin [mailto:jmartin11209@gmail.com]
Sent: Thursday, September 29, 2011 1:20 PM
To: James J Jarecki
Cc: Michaels, Adam
Subject: Jessica Martin v. American Education Services
[Ouoted text hidden]
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https:llmail.google.com/maill?ui=2&ik=0977 c6706f&view=pt&search=sent&msg= 132bae... 1016/2011
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 14 of 15 PageID #: 186
Gmail - Jessica Martin v. American Education Services
Page 1 of 1
Miss Martin <jmartin11209@gmail.com>
Jessica Martin v. American Education Services
Jessica Martin <jmartin11209@gmail.com>
Sat, Oct 1, 2011 at 12:35 AM
To: "Michaels, Adam" <michaela@pepperlaw.com>
Hello Mr. Adams,
Your pre-motion conference motion for partial dismissal was partially denied. The federal claim against the
defendant via the FCRA and the punitive and statutory damages are still held against the defendant. Please
refer to the docket report. Also, I am aware of my priviledges/rights, I have requested an Alternative Dispute
Resolution Conference today. I do anticipate winning my case in front of a the US District Judge or trial
by Jury; since I have substantial proof and facts and most importantly documentation with dates and
correspondance. I am a pro se litigant and therefore I am doing the best that I can with the legal knowledge
that I have to re-establish my perfect credit rating prior to the discovery of the credit reporting errors that
American Education Services inflicted upon me without diligently seeking to resolve my requests for proper
investigation and removal for 2 years.
I believe it is in the best interest of the defendant to seek to resolve this case through ADR conference. I
wanted an answer or some attempt for the company to explain itself and actions first prior to discussion;
however I see that it may take a long time and the trial process is lengthy. Mind you, my main objective is to
clear these errors from my credit report; not to be in court for several months. Therefore I am willing to settle.
ADR are arranged to deter high legal expenses, such as attorney fees, that may be acquired through the
lengthy legal process.
My proposal is:
1. Removal of credit reporting errors, all of the 28 late payment status on my account within 60 days. Fine:
$28,000, $1,000 for every violation
2. Punitive and Statutory Damages of $450,000
Total of $478,000 versus the 878,000, I have filed suit for.
I am willing to negotiate with the defendant without the US District Judge being the mediator or with the US
District Judge being the mediator. If the request for ADR is granted; it is up to your judgement if you would like
the US District Judge to mediate any form of settlement; however we can seek to make a settlement
now. Feel free to counteroffer. I do believe my case will stand solid by Jury or the US District Judge.
Thank you so much.
Jessica Martin
732-742-0209
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https:llmail.google.com/maill?ui=2&ik=0977c6706f&view=pt&search=sent&msg= 132bdc... 10/6/2011
Case 1:11-cv-03319-ENV-LB Document 22 Filed 10/11/11 Page 15 of 15 PageID #: 187

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