Another VIP Client Goes After Wyndham Vacation Resorts, Robert Paisola Reports

The quality is not great, but used the only camera I have.  The message is unmistakable.  Enjoy

http://www.youtube.com/watch?v=5W2TM71Ba-c&feature=g-upl
I sent the link to WVO management as well as my FB page.  Maybe I will get some positive results.  Will keep you informed.

 

Throwing rocks at the hornets nest,

Chip Slate 

Dear Mr. Paisola,

I have read so many of your articles on your web-site I feel I almost know you.  I need your help--I hope you will reach out to me.

I am writing you as a citizen of Illinois.  In May 2010, last year, I was tricked into upgrading my Wyndham Vacation Resorts timeshare. 

I told the sales representative at the time that I could not afford to upgrade, and in fact my house was in foreclosure.  However, he persuaded me that by upgrading I could rent out my extra points, and not only save my time share investment, but also contribute revenue towards saving my house. This was false. 

I went to your web-site: The Timeshare Chronicles.... and found at least 5 stories of people who had been promised they could get substantial rental income if they upgraded.... and these were people with limited means, like myself. 

At this point, my savings are tapped out, the salesman’s promises have turned out to be false, and I have not paid my timeshare mortgage or maintenance fees for several months.  For a while I was getting collection calls 10-15 times a day.  I hate to refer to my age--I am 60 years old.

What really stopped me cold, however, was a conversation I had with one of Wyndham’s collection agents.  He said if I let the timeshare go into foreclosure that the IRS would come after me for unpaid taxes.  They said there would be a 1099a issued whereby anything I had not paid to Wyndham would be considered an income gain.  This terrified me.

After a while I realized that the 1099a they are referring to would be generated by Wyndham…. and that this is their revenge on my not fulfilling on paying the timeshare contract.  I have enclosed a highlighted explanation from a consumer web-site, where a woman described her experience with the 1099a.

I have requested that Wyndham rescind the upgraded contract, and return to the prior contract that I signed in 2007.  However, I would very much appreciate your support in this matter, because I believe their actions are fraudulent.

Before I start sending you a bunch of documents, I would appreciate a response!

Thank you.

Shelley

Here We Go Again (2012 Update 1-877-517-9555)

Wyndham Worldwide, Wyndham Vacation Ownership,  Fraud Validation - Senior Management Speaks- A Robert Paisola Exclusive 2012

For Associated Press Release
For Western Capital Multimedia USA
March 10, 2012
Mr. Robert Paisola

CEO,   The Timeshare Chronicles

1-877-517-9555

*Names of victims protected by Western Capital for Litigation Purposes 

Read This Report on PISSED CONSUMER AT :http://wyndham-hotels-and-resorts.pissedconsumer.com/wyndham-worldwide-wyndham-vacation-ownership-fraud-validation-senior-management-speaks-a-rober-20120410311291.html

My name is ... (*Names of victims protected by Western Capital for Litigation Purposes)

WATCH THE WYNDHAM EMPIRE STOCK FALL.. LIVE STREAMING NYSE QUOTES.. THANKS TO WYNDHAM WORLDWIDE CEO, STEPHEN HOLMES



THE AUDIO FILES ARE BELOW

In 2007 and 2008, I was an awarded sales executive with Wyndham Vacation Resorts, Inc. employed by their Lahaina, Maui office. In the first six months of their opening on Maui, I was the top agent in every single sales category:

Robert Paisola,

I pride myself on honesty, integrity and ethics – quite ironically, the same values professed by Wyndham in just about every employment documentation and propaganda they release. 

In timeshare parlance – “I pitch it clean” and was a Senior Sales Executive, who did not rely on anyone else (a “closer”, or what have you) to complete the sale. My success was based upon creating relationships with the client and treating them like human beings – not numbers.

In 2012, I was recruited back to the Lahaina location by a Wyndham Sales Manager (also a recent re-hire, putting together a “team”) who happens to be an old friend and co-worker at the same office years before.

For the purposes of this exposé, this manager was someone who shared the same ethical belief that you don’t have to lie, cheat and steal to make a living. While I was in training, this manager who recruited me was fired for calling attention to nepotism and favoritism on the sales floor.

At that time, I had no idea how bad it had become…

Upon completion of my “training” - which in itself was a foray “into the gray”, with a focus on how to say things a certain way, essentially to “get away with it” - I was put on the sales floor – without a “team” or anyone who in any way had an interest in my success. Thus, I was limited in the ability to “close” my own deals. I was not given the opportunity to “show numbers” and I was required to use the biggest liars I have ever seen in my years in the business.

After receiving numerous items of sales “collateral” from management and witnessing the tactics that were pervasively used on the sales floor, I had a real problem with it and complained to senior management (Wyndham VP) stating that it was unnecessary to perpetrate the litany of lies I had witnessed and that I would not lie for them.

I requested that I not be required to use their “managers” to close the sale because I felt that they lied through their teeth and essentially violated the trust I had developed with my clients during the hour-and-a-half or so that I had spent with them. It was incredible to me the level of deception that these managers went to in order to “pull the card” or to complete the sale. It was one lie on top of another, for example:

COMING SOON

This document, (utilizing inflated pricing – I can assure you that no one paid these prices at the times indicated), was used to demonstrate “buy back” – Wyndham’s “first right-of-refusal” pricing. Essentially, the potential clients were told that if they bought today and they decided in the future that they did not want their timeshare anymore, Wyndham would “buy it back” for whatever the then going rate would be. This document was used to show “investment value” of their product, which is specifically not allowed by law and the terms of my Hawai’i Real Estate License – I do not have the legal right whatsoever to make that claim.

And:

These are used to create “urgency”, as in “buy today or you won’t get any of this”. This is deceptive and frankly, not true. I have personally never seen a $289 week (and if I did, I’d doubt that it would be anywhere you’d like to stay…).

“Plus Partners” is $2395. Really? Plus partners is the ability to use your points for other travel goods and/or services, thus diluting the already incredibly diluted points…

Trading Places International is NOT exclusive to Hawai’i owners, etc.

And:

These prices are used to illustrate comparative “value” to other Maui properties: These prices are completely inaccurate! (Used for no other reason than to illustrate Wyndham management’s deception – I KNOW these prices to be inaccurate!)

And:

COMING SOON

These prices are used to show grossly inflated prices that you will be required to pay if you do not purchase today. Firstly, no one pays these prices – period. Secondly, I’d like to call attention to the grossly inflated “CWP Assessment” pricing (“Maintenance fees”) demonstrated here and ask: How does one justify a huge drop in a maintenance fee that, according to Wyndham management at the site, ”are mandated to be non-profit” by the State of Hawai’i? I do not feel this can be done with any integrity whatsoever. This pricing sheet was mandated by management, but I simply could not find a credible way to present this document, and these were the only prices I was allowed to show.
COMING SOON

And:

This document illustrates “Trading Power” showing that (the upsell to) “VIP” will somehow put you to the “front of the line” for trading. “VIP” is quite simply, ownership of a certain amount of points and is irrelevant to “Trading Power”.

I could go on and on about what I witnessed and was provided by/at the hands of Wyndham Lahaina management including my being chastised for showing the potential customer the “Wyndham Book” which outlines the points actually needed to stay at their properties and the fact that numerous agents and managers actually mail the books to the clients after purchase to circumvent the Hawai’i 7-day rescission period, said rescission I understand is now better than 30% in that room! (This means that almost 1 out of 3 clients CANCELS their purchase when they got back to their hotel and actually discover what they just purchased). But now, I will call attention to an edit of a recording made at the Lahaina site between myself and Kenneth Adair – Wyndham’s site VP.: The first recording “Say what you need to say” is a Wyndham VP directing me to “say what I need to say at any cost” to put the numbers on the board “stick or kick – it’s OK until it’s not OK”. I complained, to Senior Management, Human Resources and the State of Hawai’i Department of Commerce and Consumer Affairs and was subsequently fired.

I believe for no other reason than my ethics were not in sync with current management philosophy.

Kenneth Adair , Senior Wyndham Vice President, Giving Illegal Instructions to Top Salesman
(Insert “Say What You Need To Say” mp3 file - attached)

The second recording is where I was informed of the “cruel reality” that no one, the site VP, the Director of Sales, nor any manager, cares. I was informed that I need to “take responsibility” and that “This is the hard part of this business - nobody wants to do that”.  Well, this is a major problem that I have with a publicly-traded, Fortune 1000 company telling me to “do what I need to do and say what I need to say – at any cost” – in order to ensure profit for the company… and that plainly and simply:” “Nobody cares”.
Well, you are wrong there: I care. And so do the clients that you are lying to.

Kenneth Adair , Senior Wyndham Vice President, Giving Illegal Instructions to Top Salesman

(Insert “Nobody Cares” mp3 file - attached)

The third recording is evidence that I had previously went to management requesting that I need not use “management” to close deals. I am a proven, successful agent that was previously promoted to NOT using a “closer”. It appeared to me that significant offense was taken that I had the audacity to complain. I took offense to the consistency of lies perpetrated at this office and it cost me my job.

Kenneth Adair , Senior Wyndham Vice President, Giving Illegal Instructions to Top Salesman

(Insert “Do My Own Backend” mp3 file – attached)

I have brought this all to the attention of Wyndham corporate and it appears that they do not have any concern as to the tactics of the Wyndham Lahaina sales office. Essentially, they have done nothing to curtail this unethical, deceptive and dishonest activity.

It seems that a philosophy of “profit at any cost” prevails.

It goes on to this day.

WARNING:  THIS IS A VERBATIM TRANSCRIPT OF WHAT HAS HAPPENED AT WYNDHAM. THE DOCUMENTS HAVE BEEN AUTHENTICATED, THE REST OF THE PHOTOS AND AUDIO FILES WILL BE LOADED SOON.  IF YOU ARE A VICTIM OF WYNDHAM RESORTS, PLEASE EMAIL US IMMEDIATELY (AS HAS BEEN DONE HERE) to VIP@TIMESHARECHRONICLES.COM . 

 THE WYNDHAM WORLDWIDE EXECUTIVE COMMITTEE:

Stephen P. Holmes

Chairman and Chief Executive Officer

Stephen P. Holmes is chairman and chief executive officer of Wyndham Worldwide, one of the world’s largest hospitality companies with operations in nearly 100 countries, and recently ranked by FORTUNE magazine as the most admired company in the hospitality industry.
Prior to the formation of Wyndham Worldwide in 2006, Mr. Holmes was vice chairman and a member of the board of directors of Cendant Corporation, where he oversaw hotel franchise, vehicle rental, timeshare development, timeshare exchange, and vacation rental businesses. Earlier in his career, Holmes also served as executive vice president and chief financial officer of HFS Inc. and managing director of The Blackstone Group.

In addition to his position at Wyndham Worldwide, Mr. Holmes serves as a Vice Chairman of the World Travel & Tourism Council and the Travel Business Roundtable. He is also a member of the Board of Trustees of Bucknell University, and was honored as the 2007 Hall of Leaders inductee by the U.S. Travel Association.

Geoff Ballotti

President and Chief Executive Officer
Wyndham Exchange & Rentals

Geoff Ballotti has served as president and chief executive officer, Wyndham Exchange & Rentals, since March 2008. In this role, Ballotti oversees more than 8,000 associates working in 72 offices in 33 countries.  As president and CEO, he manages Wyndham Vacation Rentals, a diverse and celebrated collection of more than 25 vacation rentals brands from around the world, and RCI, the global leader in vacation exchange with a network of more than 4,000 affiliated resorts around the world and more than 3.7 million members. Prior to joining Wyndham Worldwide, Ballotti was president of the North America division of Starwood Hotels and Resorts. Geoff also brings international and global experience to Wyndham Exchange & Rentals, having led operations for Starwood in Europe. He speaks both French and Italian.

Eric A. Danziger

President and Chief Executive Officer
Wyndham Hotel Group

Eric A. Danziger has served as President and Chief Executive Officer of Wyndham Hotel Group since December 2008. Mr. Danziger has more than 30 years of hotel industry experience, starting as a bellman at the Fairmont Hotel in San Francisco and growing into progressively senior roles in hotel operations, general management and regional operations. His most recent hospitality experience includes serving as President and Chief Operating Officer of Carlson Hotels Worldwide, President and CEO of Starwood Hotels and Resorts Worldwide, and President of Wyndham Hotels and Resorts. Prior to joining Wyndham Worldwide, Danziger was CEO of WhiteFence, an online one–stop comparison shopping and transaction site for home services, and before that, president and CEO of ZipRealty, a national, full–service real estate brokerage.

Franz S. Hanning

President and Chief Executive Officer
Wyndham Vacation Ownership

Franz S. Hanning has served as President and Chief Executive Officer, Wyndham Vacation Ownership since our separation from Cendant in July 2006. Mr. Hanning was the Chief Executive Officer of Cendant's Timeshare Resort Group from March 2005 until our separation from Cendant in July 2006. Mr. Hanning served as President and Chief Executive Officer of Fairfield Resorts, Inc. (which has been renamed Wyndham Vacation Resorts, Inc.) from April 2001, when Cendant acquired Fairfield, to March 2005 and as President and Chief Executive Officer of Trendwest Resorts, Inc. (which has been renamed Wyndham Resort Development Corporation) from August 2004 to March 2005. Mr. Hanning joined Fairfield in 1982 and held several key leadership positions with Fairfield, including Regional Vice President, Executive Vice President of Sales and Chief Operating Officer.

Tom Anderson

Executive Vice President and Chief Real Estate Development Officer

Tom Anderson has served as our Executive Vice President and Chief Real Estate Development Officer since our separation from Cendant in July 2006. From April 2003 until July 2006, Mr. Anderson was Executive Vice President, Strategic Acquisitions and Development of Cendant's Timeshare Resort Group. From January 2000 until February 2003, Mr. Anderson was Senior Vice President, Corporate Real Estate for Cendant Corporation. From November 1998 until December 1999, Mr. Anderson was Vice President of Real Estate Services, Coldwell Banker Commercial. From March 1995 to October 1998, Mr. Anderson was General Manager of American Asset Corporation, a full service real estate developer based in Charlotte, North Carolina. From June 1990 until February 1995, Mr. Anderson was Vice President of Commercial Lending for BB&T Corporation in Charlotte, North Carolina.

Thomas G. Conforti

Executive Vice President
Chief Financial Officer

Thomas G. Conforti has served as Executive Vice President and Chief Financial Officer since September 2009. Prior to his appointment to Wyndham Worldwide, Mr. Conforti was chief financial officer of DineEquity Inc., the publicly held company which is the franchisor and operator of restaurants under the Applebee's Neighborhood Grill & Bar and IHOP brands. Earlier in his career, Conforti held a number of general management, financial and strategic roles over a ten-year period in the Consumer Products Division of the Walt Disney Company. He also held numerous finance and strategy roles within the College Textbook Publishing Division of CBS and the Soft Drink Division of Pepsico.

Mary R. Falvey

Executive Vice President
Chief Human Resources Officer

As executive vice president and chief human resources officer for Wyndham Worldwide, Mary Falvey leads a wide range of human resources, marketing, corporate social responsibility, and operations functions across the global enterprise of approximately 27,800 associates in nearly 100 countries, including human resources, talent and leadership development, marketing and corporate communications, sustainability, diversity, philanthropy, employee health and wellness, security, real estate development, and facility operations.
Prior to the spin-off which created Wyndham Worldwide, Falvey served in several senior leadership positions at Cendant Corporation, including executive vice president of global human resources for RCI and vice president of human resources for the hotel division.  Earlier in her career, she held various human resources positions at Nabisco. She also currently serves on the executive committee of the Starlight Children’s Foundation, one of Wishes by Wyndham’s signature charities, and as co-chair of Big Brothers, Big Sisters of Morris, Bergen, Passaic, and Sussex Counties in New Jersey.

Scott G. McLester

Executive Vice President
General Counsel

Scott G. McLester has served as our Executive Vice President and General Counsel since our separation from Cendant in July 2006. Mr. McLester was Senior Vice President, Legal for Cendant from April 2004 until our separation from Cendant in July 2006. Mr. McLester was Group Vice President, Legal for Cendant from March 2002 to April 2004, Vice President, Legal for Cendant from February 2001 to March 2002 and Senior Counsel for Cendant from June 2000 to February 2001. Prior to joining Cendant, Mr. McLester was a Vice President in the Law Department of Merrill Lynch in New York and a partner with the law firm of Carpenter, Bennett and Morrissey in Newark, New Jersey.

Nicola Rossi

Senior Vice President and Chief Accounting Officer

Nicola Rossi has served as our Senior Vice President and Chief Accounting Officer since our separation from Cendant in July 2006. Mr. Rossi was Vice President and Controller of Cendant's Hotel Group from June 2004 until our separation from Cendant in July 2006. From April 2002 to June 2004, Mr. Rossi served as Vice President, Corporate Finance for Cendant. From April 2000 to April 2002, Mr. Rossi was Corporate Controller of Jacuzzi Brands, Inc., a bath and plumbing products company, and was Assistant Corporate Controller from June 1999 to March 2000. From November 1995 to May 1999, Mr. Rossi was Director of Corporate Accounting of The Great Atlantic & Pacific Tea Company, Inc. From 1988 to 1995, Mr. Rossi held various positions, from staff accountant to manager, with Deloitte & Touche LLP.

1. My Wyndham Lawsuit |

   mywyndhamlawsuit.com/

   Chameleon Logo. Home · About Time · stand by · The Latest · Where Is Everything? Photos. Twitter Rss Facebook. The Latest About Time Where Is Everything?

2. Wyndham Hotels and Resorts - WYNDHAM LAWSUIT IN TEXAS

   wyndham-hotels-and-resorts.pissedconsumer.com/wyndham-lawsuit-...

   Dec 5, 2010 – Visit www.mtwyndhamlawsuit.com This is some strong stuff. For anyone who feels they have been scammed in anyway by these basxxxxx!

3. Wyndham Hotels and Resorts @ Pissed Consumer

   wyndham-hotels-and-resorts.pissedconsumer.com/

   Wyndham Hotels and Resorts Complaints: Our expected arrival was 8 pm. We were looking forward to a comfortable night in your hotel and my companion’s ...

   You visited this page on 4/10/12.

4. Vacation pressure leads couple to sue Wyndham Resorts | Madison ...

   www.madisonrecord.com › News › St. Clair County

   Dec 17, 2008 – Wyndham Vacation Resorts is being sued by a couple who alleges they were misled into purchasing a vacation package they did not want.

5. Wyndham Class Action Lawsuit - Girard Gibbs LLP

   www.girardgibbs.com › Cases & Results

   Wyndham Resorts / Worldmark Class Action Lawsuit. Case Update: Court Approves Settlement. The terms and conditions of the proposed Settlement are set ...

6. Wyndham Vacation Resorts | Ripoff Report | Complaints Reviews ...

   www.ripoffreport.com/directory/Wyndham-Vacation-Resorts.aspx

   Wyndham Vacation Resorts | Ripoff Report | Complaints Reviews Scams Lawsuits Frauds Reported. Company Directory | Wyndham Vacation Resorts ...

7. Consumer complaints about Wyndham Vacation Resorts

   www.consumeraffairs.com/travel/wyndham_vacation_resorts.html

   Consumer complaints about Wyndham Vacation Resorts. ... We would greatly enjoy having a class action lawsuit brought against Wyndham, but from everything ...

8. The Wyndham Timeshare Company Lawsuit Gets Underway: David ...

   www.zimbio.com/.../Wyndham+Timeshare+Company+Lawsuit+Gets...

   Dec 25, 2010 – This site explores what happens when a former employee of a very large corporation is sued by them. Wyndham vacation resorts is, by their ...

9. wyndham resorts lawsuit - Robert Paisola: The Time Share ...

   timesharescamsupdate.blogspot.com/.../wyndham%20resorts%20laws...

10. Possible new Wyndham lawsuit on the horizon... - Timeshare Forums

    www.timeshareforums.com › ... › Wyndham/Fairfield Resorts

    Sep 16, 2010 – One of the largest individual Wyndham point owners is working with several firms to investigate the potential of a lawsuit to challenge some of ...

Vacation pressure leads couple to sue Wyndham Resorts, Posted By Robert Paisola

The Full Lawsuit against Wyndham resorts is Annotated Below:

This is a pre-story on a story that we are doing on Wyndham that will soon be published. We have sent emails to 14 top Wyndham Executives and have not received a reply on our inquiries. We will keep you advised as this story develops.
Robert Paisola
Editor
The Time Share Chronicles

Wyndham Vacation Resorts is being sued by a couple who alleges they were misled into purchasing a vacation package they did not want. We are gathering the legal pleadings to post for your review now.


Roger L. and Catherine A. Cole bought the package after taking Wyndham Vacation Resorts up on an offer of an essentially free vacation in Branson, Mo., in early 2007, according to the complaint filed Dec. 12 in St. Clair County Circuit Court.

In order to receive the vacation, all the Coles had to do was listen to a 90-minute presentation outlining the benefits of purchasing a Vacation Ownership Interest from Wyndham, the suit states.

At the end of the May 7, 2007, presentation, the Coles expressed a desire to learn more about the offer, they claim.

When the Coles asked about the offer, Wyndham's employees began to engage in numerous deceptive acts and practices, according to the complaint.

For example, the employees immediately placed an assortment of contracts and other agreements in front of the Coles and pressured them to sign the documents, the suit states.

"In the event plaintiffs expressed hesitation, rather than giving plaintiffs any time and space for contemplation they were immediately introduced to a more experienced agent of superior rand and broader deal making authority," the suit states.

Employees also neglected to provide the Coles with any time to read and fully comprehend what they were being pressured to sign and failed to explain to the Coles several material items in the contracts and agreements including the points that the Coles would acquire were non-transferable except to others possessing a similar "Vacation Ownership Interest," or to approved guests older than 21, the Coles claim.

Other items that were not explained to the Coles included that even transferring under the terms came with a fee, points unused at the end of each annual cycle could not be transferred to cover the cost of monthly payments, the contracts bore only "a trace resemblance to the terms explained during the presentation," the Coles would not be allowed to rent their time share out to others unless they acquired 500,000 points and the Coles would only have five days to rescind their contract, according to the complaint.

Because of the employees' deception, the Coles purchased a Vacation Ownership Interest with "very little understanding of that which they were actually signing," the suit states.

Again in June, the Coles traveled to Orlando, Florida, on another solicited vacation to explore the possibility of buying another 192,000 points so they could rent or transfer their points and ease their financial burden, they claim.

Employees again engaged in deceptive practices by withholding from the Coles the fact that the Coles would only be able to rent in exchange for 40 percent of the ultimate rent amount, according to the complaint.

"Plaintiffs have been fraudulently deprived of honestly-earned income, a deprivation which continues as monthly payments continue to become due, in addition to maintenance payments," the suit states.

Wyndham has not allowed the Coles to be released from their obligation, they claim.

So, they have also suffered extraordinary mental anguish and have become liable for large amounts of money, according to the complaint.

In the two-count suit, the Coles are seeking $150,000, plus costs.

They are represented by Thomas Q. Keefe, III., of Belleville, Illinois.

St. Clair County Circuit Court case number: 08-L-632.

12/17/2008 9:55 AM
By Kelly Holleran

Now for the Lawsuit!

IN THE CIRCUIT COURT

TWENTIETH JUDICIAL CIRCUIT

ST. CLAIR COUNTY, ILLINOIS

ROGER L. COLE AND CATHERINE A. COLE )

)

Plaintiffs, )

)

v. ) No. ___________

)

WYNDHAM VACATION RESORTS, INC., a )

corporation )

)

Defendants. )

COMPLAINT

COUNT I

COMES NOW the plaintiffs, by and through their attorneys, THOMAS Q. KEEFE, JR., P.C., and for Count I of their Complaint against the defendant, Wyndham Vacation Resorts, Inc., state as follows:

1. That this is an action under the Illinois Consumer Fraud Act, 815 ILCS 502/2, et seq and 505/10a et seq, which was in effect at all times herein mentioned.

2. That at all times herein mentioned the plaintiffs, Roger and Catherine Cole, were citizens and residents of the state of Illinois.

3. That at all times herein mentioned the defendant, Wyndham Vacation Resorts, Inc., was a corporation authorized and doing business in Illinois, with offices and other locations operating throughout Illinois.

4. That in early 2007, defendant solicited plaintiffs with an offer of an essentially free vacation in Branson, Missouri; all that was required of plaintiffs was an agreement to meet with defendant’s agent for a ninety minute presentation outlining the supposed benefits of purchasing a Vacation Ownership Interest, (i.e. a “timeshare”) from defendant.

5. That plaintiffs accepted, and the presentation occurred on May 7, 2007; at the conclusion of the presentation, plaintiffs expressed a desire to learn more about defendant’s offer.

6. That at this point, and at all times herein mentioned, defendant - by and through their agents, sub-agents, and/or employees - engaged in numerous deceptive acts and/or practices, including but not limited to:

a) immediately placing an assortment of contracts and other agreements in front of plaintiffs and pressuring them to sign; in the event plaintiffs expressed hesitation, rather than giving plaintiffs any time and space for contemplation they were immediately introduced to a more experienced agent of superior rank and broader deal making authority;

b) neglecting to provide plaintiffs with any - much less sufficient - time to read and fully comprehend that which what they were being pressured to sign;

c) neglecting to explain to plaintiffs several material terms in the contracts and agreements, including but not limited to:

i. That the “Points” which plaintiffs would acquire (308,000 from this initial agreement), which were ostensibly intended to provide flexibility in how plaintiffs used their “Vacation Ownership Interest”, were actually non-transferrable except to others possessing a similar “Vacation Ownership Interest”, or to approved guests over the age of 21;

ii. That, further, even transferring under the above-elucidated terms came with a fee;

iii. That Points unused at the end of each annual cycle (understood to expire) could not even be transferred to cover the cost of their monthly payments;

iv. That - overall - the contracts and agreements plaintiffs were being pressured to sign bore only a trace resemblance to the terms explained during the presentation;

v. That, in the event of purchase, plaintiffs would not be permitted to rent their time share out to others unless they first acquired a total of 500,000 points (192,000 more than what plaintiffs signed up for);

vi. That, in the event of purchase, plaintiffs would only have five days to recind their contract (insufficient time to fully review the terms, particularly while still on vacation), and further that any such recision was only effective when received by defendant;

vii. That reservations cancelled two weeks or less prior to check-in date resulted in forfeiture of all points used to make the reservation;

viii. That defendant’s “network administrator” retained absolute discretion to cancel a member’s reservation due to any type of natural disaster - and doing so does not entitle that member to a refund of the points designated for that particular trip;

ix. That the aforementioned network administrator is vested with unfettered discretion to modify the Terms and Conditions at his or her whim, and without advance notice to or input from the members.

7. That each of the foregoing deceptive acts, practices, and/or omissions occurred in the course of conduct involving trade or commerce, and was undertaken with the intent that plaintiffs rely on them.

8. That as a direct and proximate result of the foregoing deceptive acts, practices, and/or omissions on the part of defendant, their agents, sub-agents, or employees, as aforesaid, plaintiffs purchased a Vacation Ownership Interest from defendant, and did so with very little understanding of that which they were actually signing. Plaintiffs were led to believe that they were agreeing to those terms said forth in the presentation; unbeknownst to them, the actual terms bore little resemblance to that which was explained to them. Plaintiffs have been fraudulently deprived of honestly-earned income, a deprivation which continues as monthly payments continue to become due, in addition to maintenance payments. Defendants have refused plaintiffs’ repeated efforts to release themselves from this fraudulently-obtained obligation. In addition to monetary deprivation, plaintiffs have suffered - and continue to suffer - extraordinary mental anguish, and have become liable for large sums of money in compensation, all to their damage in a substantial amount.

WHEREFORE, plaintiffs demand judgment from the defendant in an amount greater than SEVENTY-FIVE THOUSAND DOLLARS ($75,000.00), plus costs.

COUNT II

COMES NOW the plaintiffs, by and through their attorneys, THOMAS Q. KEEFE, JR., P.C., and for Count II of their Complaint against the defendant, Wyndham Vacation Resorts, Inc., state as follows:

1.-8. Plaintiffs hereby adopt and incorporate paragraphs 1 through and including 8 of Count I as and for paragraphs 1 through and including 8 of Count II.

9. That in June 2008, plaintiffs, struggling with payments and newly familiar with the rental provisions withheld from them in May 2007, traveled to Orlando, Florida on another solicited vacation; plaintiffs did so to explore the possibility of purchasing another 192,000 points so that they could rent or transfer their points and thereby ease their financial burden.

10. That, following both another presentation and the same strong armed tactics outlined in subparagraphs 8(a) and (b), supra, defendants - by and through their agents, sub-agents, and/or employees - engaged in the following deceptive act and/or practice:

a) withheld from plaintiffs the fact that - in the event plaintiff acquired the requisite total of 500,000 points and with defendant’s help in renting - defendant would only do so in exchange for 40% of the ultimate rental amount.

11.-12. Plaintiffs adopt and incorporate paragraphs 7 and including 8 of Count I as and for paragraphs 11 through and including 12 of Count II.

WHEREFORE, plaintiffs demand judgment from the defendant in an amount greater than SEVENTY-FIVE THOUSAND DOLLARS ($75,000.00), plus costs.

______________________________

THOMAS Q. KEEFE, III

IL Reg. No. 6294376

Thomas Q. Keefe, Jr., P.C.

Attorneys for the Plaintiff

THOMAS Q. KEEFE, JR., P.C.

ATTORNEY AT LAW

#6 EXECUTIVE WOODS COURT

BELLEVILLE, ILLINOIS 62226

618/236-2221