CHRISTOPHER KING, J.D.

ARLINGTON COMPLIANCE
kingcast955@icloud.com
617.543.8085

April 3, 2024

Re: Immediate Cancellation of Lynese Cramer Fully-Vested 6,000 Point Timeshare.

Good Day,

By way of introduction I am first and foremost a Journalist. At times I am a Consumer Advocate based on what I
discover in my research, and my research is quite thorough. I’ve edited a statewide weekly in Cincinnati and wrote
for a daily in Indianapolis prior to law school. Over the years I have also managed a title company and performed
zoning and permitting in the wireless arena, which brings me to this particular situation:

In all of my endeavors I always took care to examine things from the little people’s perspective, that led me to
working as a private citizen in programs like the Washington Foreclosure Fairness Program with local paralegals
and local licensed counsel where we saved a lot of homes. We made life livable for people who were often in
danger through no fault of their own.

We tried until the cows came home to help opposing sides see the wisdom in putting down their armor and
resolving this through extrajudicial means whenever possible.

Ms. Cramer comes to me through that network of people and while her case is not exactly a foreclosure I know
that’s what happens in timeshares when disputes arise, and frankly I cannot think of a situation that lends itself to
settlement more than this one so I told her I would try to help work this out between you two since the lawyer she
started with is not able to continue the case.

This is a woman who in in the caregiving industry and taking care of her family right now, including her mother,
whom I had the privilege of meeting last week. They live modestly and there’s not a lot of money to be throwing
around. The timeshare was a huge purchase for her back in the early 90’s and she has long since paid oT the
Principal balance and has 6,000 points for a mid-level annual rental.

Unfortunately it is everyone’s knowledge that these timeshares are basically illusory these days as was proved by
the research that was conducted upstream from me as your company steered Ms. Cramer away from seeking
Counsel. I think she was correct to seek Counsel but at this point honestly what do either of you stand to gain by
litigation?

She could potentially win damages against you especially since you never provided her the cancellation
documents as promised (above and beyond the inability to obtain any timely rentals).

Obviously you are under no obligation to agree with me or to resolve this matter. Ms. Cramer is similarly under no
obligation to agree to resolve this matter. But why wouldn’t you? You’ve earned your money on Ms. Cramer. She just
wants out and you are stalling – according to many believable accounts and by your actions witnessed here. Not
only that, she tried logging into her Trendwest account and it didn't work...the website doesn’t even work; she tried
to reset her password and didn't get an email to do even complete that task. It is time to split the sheets and
everyone move along here; Ms. Cramer informs that she is signing the DocuSign cancellation paperwork that
she received yesterday, and that if you actually follow through promptly this month without further charges
she will not seek any Damages.

Sincerely, Christopher King, JD

 JUSTICE OF THE PEACE COURT
SMALL CLAIMS DIVISION
NEW CASTLE COUNTY

LYNESE CRAMER, ) CASE NO ______________________

Plaintiff, ) JUDGE _______________________

v. )

WYNDHAM HOTELS RESORT DEVELOPMENT

f/k/a TRENDWEST RESORTS, INC.
3411 Silverstone Road )
Tatnall Building
Suite 104 )
Wilmington, DE 19810,

Defendant. )

COMPLAINT

PARTIES

1. PlainJff is a Washington resident who purchased a Timeshare in or about 1993. She

has long since paid off her total financial commitment of the original contract and has 6,000
credits.
2. Defendant Wyndham VacaJon Resorts is the current Successor in Interest by Merger or
AcquisiJon to the company formerly known as Trendwest Resorts, at all Jmes doing substanJal
business in the Forum State and County. Between them they have been successfully sued by
state A[orneys General and further involved as Defendant to successful Class AcJon liJgaJon for
false and decepJve consumer pracJces.

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 JURISDICTION AND VENUE

3. This is a Court of general JurisdicJon having authority to review all claims presented in this
lawsuit. Defendant is headquartered in this State and County.
FACTS

4. In or about 1993 PlainJff entered into a Jmeshare agreement with an enJty known as
Trendwest.
5. Her agreement was for one week at mid-level or medium use.
6. PlainJff typically exercised her opJons during Christmas Holiday season or at other off-peak
Jmes.
7. The contract did not require PlainJff to remain locked into the agreement for unreasonable
amounts of Jme aaer she completed the scheduled payments.
8. She honored her end of the contract and completed the schedule payments years ago.
9. She also conJnued Jmely paying the annual maintenance fees most recently in the amount of
approximately $918.00/annum.
10. In recent years as the corporate enJJes shiaed from Trendwest to WorldMark by Wyndham,
which on informaJon and belief PlainJff finds to be a subsidiary of the lead named Defendant.
11. Along the way PlainJff noJced that the customer service was now below par, an asserJon
supported by relevant liJgaJon that will be noted below.
12. At one point the Wyndham enJty even refused her any consideraJon when she was at one of
their locaJons in Leavenworth, Washington and her father died in Sea[le.
13. Worse than that is the undeniable fact that PlainJff and people similarly-situated simply cannot
access their purported assets, as noted by the California law firms of Girard Gibbs LLP and Gersh
& Helfrich, LLC:
h[ps://www.classlawgroup.com/wyndham-se[lement
h[ps://www.classlawgroup.com/docs/cases/85_wyndham%20se[lement%20agreement.pdf
Wixon v. Wyndham Resort Development Corp. (f/k/a Trendwest Resorts, Inc.) C-07-02361 JSW
(ND. Cal 2007).

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 Many consumers are reporting in 2018 that they believe they have been scammed into
purchasing a Wyndham Resorts timeshare and may even be considering a Wyndham class action
lawsuit. One consumer from Louisiana says that she and her husband enter a contract for a
Wyndham timeshare, which they could never use and couldn’t get out of the contract. She says:

There are never rooms available. I have literally tried to book through Club Wyndham
and told no availability and gone through Expedia and able to book. NOT WORTH THE
MONEY! I was told by the [sales representative] AND her manager when we bought that
we could cancel at any time because Wyndham realized that being trapped in a contract
was a pain point for time-share buyers and they wanted to eliminate that stigma. Guess
what I was told when I tried to cancel. Contract says you can’t.

Another consumer from Missouri says that you pay Wyndham for flexibility, but have to book
your vacation years in advance:

Wyndham will lie and cheat to get you to buy a timeshare. They will promise things that
are a lie, and by the time you realize it, it is too late. We tried to use it, and unless you
know a year in advance you can’t book anywhere.

14. On or about January 10, 2024, PlainJff decided to terminate the relaJonship, surrendering her
Timeshare.
15. Defendant promised her that she could terminate the relaJonship by way of the “CerJfied Exit
by Wyndham” program and directly told her that they would bargain in Good Faith as they
simultaneously asked her not to seek consultaOon from an APorney.
16. The emails from January 10, 2024 and January 23, 2024 prove PlainJff’s point. See Appendix A.
17. Defendant’s representaJon was made with Bad Faith intent, and Defendant had no intenJon of
working in Good Faith with PlainJff.
18. Instead, Defendant conJnued to stall PlainJff, issuing propaganda seeking $40.20. Appendix B.
19. Not only that, she tried logging into her Trendwest account and it didn't work...the website doesn’t
even work; she tried to reset her password and didn't get an email to do even complete that task.
20. Here is what happened when PlainJff a[empted to cancel:
a). PlainJff could not even navigate the new website. The new website indicates it is booked
up for 3 years but she could go to hotels but PlainJff can obtain a hotel on her own at
be[er rates, so the Jmeshare is effecJvely worthless.
b). PlainJff Called Jan 10 – close out my account, no more maintenance. “That’s a different
department.”
c). “I just want to quit.”

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 d). “You can sell it.”1

e). “I just want out. I’ve paid up and current and I want to cancel.”

f). You can cancel we will send out document.. notarize and get back to us.

g). Nothing came.

h). PlainJff calls back repeatedly and is put on interminable holds.

i). When she finally spoke with a human she is told “Oh it could take up to 7-8 weeks to get
paperwork out to you. You have to wait 3 more weeks.

21. Defendant is bilking its owners not only for an increased $40 fee, but by forcibly keeping people
in their Jmeshares for an enJre quarter of a year they are unjustly enriching their coffers by
untold amounts of money: PlainJff alone would incur $40/mo. For 3 months, for $120 as well as
another $250 pro rata of the exisJng annual cost of over $900.00.
22. Wyndham materials indicate nearly one million owners:
h[ps://www.wyndhamdesJnaJons.com/content/dam/wyndham/wynd-investor-site/news-and-
media/102319-media-fact-sheet.pdf
• Own: Through Wyndham DesJnaJons’ contemporary take on tradiJonal Jmeshare, the
company’s vacaJon clubs — including Club Wyndham®, WorldMark® by Wyndham,
Margaritaville VacaJon Club® by Wyndham, PresidenJal Reserve by Wyndham, and Shell
VacaJons Club — offer travelers the chance to own their vacaJon and explore places they’ve
never visited before, year aaer year. Nearly 900,000 owners enjoy stays in a home away from
home, featuring spacious suites with separate bedrooms, fully-equipped kitchens, living and
dining areas, as well as resort-style ameniJes and services.

23. If ten per cent of its owners wish to terminate then, 90,000 x $375.00 results in a gain of
$33,750,000 so Defendant has a vested interest in stalling disengagement and it does so with a
vengeance.
24. PlainJff had placed reasonable reliance on what seemed to be a Good Faith response, but to her
detriment she instead received promises that she would receive paperwork that she would have
to notarize and return; these documents were supposed to arrive shortly, to wit:

1
Plainti? believes she can substantiate the allegations made at a certain timeshare website that Defendant
has orchestrated a network of pre-selected partners who directly benefit from these sales in another cozy
and questionable, if not illegal operation.

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 This letter is to recap that you are voluntarily agreeing to participate in the Certified Exit by
Wyndham program and understand and agree to the following requirements as we discussed
today.

Maintenance Fee: Must be and stay current until the process is complete. Any fees paid are not
refundable.

Documentation to return inventory: You understand that you will receive by email/mail
documentation to return your inventory within 7 weeks. These documents must be signed,
notarized, and returned within the number of days indicated in the documentation. Please keep
in mind the sooner the documentation is returned the earlier the process may be completed.
Once the document is received, it may take within 11 weeks for documents to be approved and
the cancellation to be completed.

25. PlainJff did not receive any exit documents, hence the second email seen at Appendix A.
26. PlainJff was next told that the process could take eleven (11) more weeks, which is completely
in line with the fact pa[ern that stretches back decades to a $4M se[lement when the California
A[orney General sued them in People of California v. Trendwest, (San Mateo 2003).
h[ps://oag.ca.gov/system/files/a[achments/press_releases/03-134_Complaint.pdf
https://www.latimes.com/archives/la-xpm-2003-oct-30-fi-trendwest30-story.html
BUSINESS
Trendwest Resorts Settles State Lawsuit
BY E. SCOTT RECKARD
OCT. 30, 2003 12 AM PT

Time share operator Trendwest Resorts Inc. agreed Wednesday to pay more than $4 million to
settle a lawsuit filed by state officials who alleged it misrepresented products and customers’
rights to cancel contracts, disregarded valid requests to cancel and failed to honor “do-not-call”
requests.

Redmond, Wash.-based Trendwest, the third-largest time share company, is owned by New
York-based Cendant Corp., whose brands include Ramada, Days Inn, Avis, Coldwell Banker and
Century 21. It operates 48 time share properties in the western United States, Mexico, Canada
and the South Pacific, including facilities in Big Bear, Palm Springs and Oceanside…….

The action listed 16 types of false and misleading statements and 28 practices that violated a
state fair-practices law, including telling consumers they had won specific prizes when they had
not, misrepresenting time share purchases as a good investment and hiding costs for exchange
programs, maintenance and association dues.

In a statement, Trendwest said the settlement “reflects our company’s commitment to respond
effectively to any and all consumer concerns.” It said it had improved its policies and
procedures, had made its employees and vendors more accountable and had repaid many of
the customers who complained.

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 27. The cancellaJon process is at once illusory and abusive and involves patently Unconscionable
pracJces in the applicaJon of Adhesion Clause contracts.

28. PlainJff is suing under Washington’s Timeshare RegulaJon Statute RCW §64.36.210 and for a
violaJon of Washington’s Consumer ProtecJon Act RCW §19.86.20 as well.2

2
If Plainti? is compelled to file suit in Delaware the Delaware Court will hear all Claims based on prevailing
Washington and/or 9th Circuit law.

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 CLAIMS

1. Specific Performance.

The terms of the original contract did not mandate that Defendant could hold PlainJff hostage
for months on end aaer she paid off her Jmeshare.

2. Unjust Enrichment.

The acJons of Defendants, by intenJonally dragging out the CancellaJon process, is enjoying an
Unjust Enrichment

3. Unconscionabilty.

The terms of, and applicaJon of, any contractual arrangements are dictated solely by a global
enJty with extremely unequal arms’ lengths against PlainJff and it has used, and conJnues to
use its power advantage to unfairly exploit and abuse PlainJff and countless others in her
posiJon.

4. Promissory Estoppel.

Any and all promises made to PlainJff about cancellaJon have been shown to be bogus both by
the le[er and by (lack of) execuJon; for example she never even received the paperwork
requisite to iniJate the ByzanJne cancellaJon process in the first place. Moreover, the complete
lack of properJes available is yet another specific promise lea unfulfilled.

5. RCW §64.36.210.

RCW 64.36.210 Unlawful acts—Penalties.

(1) It is unlawful for any person in connection with the offer, sale, or lease of any timeshare in
the state:

(a) To make any untrue or misleading statement of a material fact, or to omit a material fact;

(b) To employ any device, scheme, or artifice to defraud;

(c) To engage in any act, practice, or course of business which operates or would operate as a
fraud or deceit upon any person….

The individual and combined actions

6. RCW 19.86.020.

RCW 19.86.020 Unfair competition, practices, declared unlawful.

The failure to have any funcJonality to the corporate website, the years-long waitlist for
available properJes even at mid-Jer levels, and the gamesmanship involved in the cancellaJon
stall game all complete the picture of a violaJon under this Statute.

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 DAMAGES

1. All costs sustained in bringing this AcJon.

2. Treble Damages for the RCW violaJons.

Respecwully submi[ed,

____________________
Lynese Cramer
PlainJff pro se