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Home My WebLink About07-5756 STOCK & GRIMES, LLP gy: EDWARD STACK, ESQUIRE I.D.# 13657 304 Nest Avenue. Jenkintown, PA 19046 (215) 576-1900 DISCOVER BANK, ISSUER OF DISCOVER CARD, BY ITS AGENT DISCOVER FINANCIAL SERVICES LLC P.O. Box 6011 Dover, DE 19903-6011 vs. NATALIE Y. JACKSON 615 Mt. Rock Road Carlisle, PA 17015 CIVIL ACrlal~i "NOTICE" Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNT Y CIVIL ACTION-LAW No . Q'1- 5~5(v C;v~ l Term. "AVISO" "Le ham demandado a usted en la Corte. Si usted quiere defenderse de estas demandas ex- puestas en las paginas siguientes, usted.tiene veinte (20) dias de plazo al partir de la fecha de la demanda y Ia notificacion. Hace falta asentar una com parencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita su.s defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, Ia Corte puede decidir a favor del demandante y requiere que usted cum pla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted." HAVE A LAWYER OR CANNOT AFFORD ONE, "LLEVE ESTA DEMANDA A UN ABO- GO TO OR TELEPHONE THE OFFICE .SET GADO INMEDIATAMENTE. SI N0 TIENE ABO-. F=ORTH BELOW TO FIND OUT WHERE YOU GADO O SI NOTIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PER- C.AN GET LEGAL HELP. "You have been. sued in court. If you wish to'defend against the claims set -forth in the fol- lowing pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appdarance person- ally or by attorney and filing in writing with the court your defenses or objections to the claim s set .forth against you. You are warned that ~if you fail to do so the case may proceed without you and a judgment may .be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. "YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT SONA 0 LLAME POR TELEFONO A LA OFI- CINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO ARA AVERIGUAR DONDE SE PUEDE COHSE lIR ASISTENCI~~ LEGAL. LAWYER CE SERVICES Court administrator -- Cumberland County Courthouse 4th Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW CIVIL ACTION COMPLAINT IN ASSUMPSIT 1. Plaintiff, Discover Bank, issuer of Discover STOCK & GRIMES, LLP BY: EDWARD STOCK, ESQUIRE I.D. #13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 DISCOVER DISCOVER DISCOVER LLC P.O. BOX Dover, D BANK, ISSUER OF CARD, BY ITS AGENT FINANCIAL SERVICES, 6011 19903-6011 Plaintiff vs. NATALIE Y. JACKSON 615 Mt. Rock Road Carlisle, PA 17015 Card, by its agent Discover Financial Services, LLC, is a duly organized banking institution under the laws of the State of Delaware and has a principal place of business at the address contained in the above caption. 2. Defendant(s), Natalie Y. Jackson, is an adult individual and resides at the address contained in the above caption. 3. After application by the Defendant(s) to the Plaintiff for a credit card account, which application was approved by the Plaintiff, the Plaintiff issued a credit card to the Defendant(s) so that the Defendant(s) could make purchases from merchants, on credit, who had established a business relationship with the Plaintiff in regard to the same. 4. Thereafter, the Defendant(s) utilized the said credit card on various and sundry occasions. 5. Plaintiff attaches hereto as Exhibit "A" to this Complaint, a true and correct copy of the last monthly statement in regard to the activities in connection with the Defendant's account and also attaches hereto as Exhibit "B" to this Complaint, an Affidavit from the Plaintiff attesting to the present balance due the Plaintiff from the Defendant(s) in regard to the said account. 6. The present outstanding balance which is due on the account(s) is $12,434.78; and, although repeated requests and demands have been made upon the Defendant(s) to satisfy the same in accordance with the terms and conditions of the credit card agreement(s), the Defendant(s) has/have and still refuse(s) to pay the same. 7. As a further result of Defendant(s) breach of the agreement for repayment of the account balance, Plaintiff is entitled to reasonable attorney collection fees. 8. Plaintiff's investigation has determined that the Defendant is not in the military service. 9. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WHEREFORE, Plaintiff, Discover Bank, issuer of Discover Card, by its agent Discover Financial Services, LLC, demands Judgment against the Defendant(s), Natalie Y. Jackson, in the sum amount of $15,543.48 (principal sum of $12,434.78 and attorneys fees of $3,108.70) with interest a ~: r ,' DATE: ~ EDWARD '" VERIFICATION The undersigned, EDWARD STOCK, ESQUIRE, hereby states that he is the attorney for the Plaintiff who is located outside this jurisdiction and in order to file the within document in an expedient and timely manner, he is authorized to take this Verification on behalf of the said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his knowledge, information and belief, based upon information provided to him by the Plaintiff. A Verification signed by the Plaintiff will be provided to Defendant or counsel for Defendant upon request. The undersigned understands that false statements herein are made subject to the penalties of 18 P.A.C.S..A. § 4904, relating to unsworn falsification to authorities. /'^ ~J New Galante Minimum Payment Uue Account Number 6U 1 1 UU18 '1852 3589 , •®~S`,~+ Y ER $0.00 ~, $2,490.00 Enter Amount Enclosed Below CARD -------- -- Payment Due Date May 29, 2007 30 SDSN6A01 0003404 NATALIE JACKSON PO BOX 13 NEWVILLE PA 17241-0013 Paperless Statements are a great way to keep track of your Discover® Card activity, and allow you to control when and where yyou view your information. Visit Discovercard.comlps PO BOX 15251 ~~~"'~~""'~~'~~"'~"'~~ WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Print change in space ~rrr~~lrlrr~rrlr~ri~rr~~irr~r~rrr~r~r~r~rrrr~~r~r~rrn~~~r~rr~ above, or go to Discovercard.com. Print your a-mail address to receive important Account information and special offers. 000006011002828523589000000000000000249000 Discover More Card Account Summary Closing Date: April 30, 2007 page 1 of 1 'Account Number 6011 0028 2852 3589 Previous Balance $12,434.78 ;Payment Due Date May 29, 2007 Payments And Credits - 12,434.78 Minimum Payment Due $2,490.00 Purchases + 0.00 Credit Limit $10,000.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $5,000.00 Finance Charges + 0.00 Cash Credit Available $0.00 _ New Balance = $0.00 CaShback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 -Cashbaek Bonus® Anniversary Available to Redeem _ - .. 3 0.00 Date: October 25 How Can We Hel You? For Account Inquiries, writs to us at . p Please have our Discover Card available. Y Discover More Card, PO Box 30943 Salt Lake City, UT 84130 Manage your account online at Discovercard.com TDD (ielxommunicotions Device For the Deaf1: Customer Service: 1.800-DISCOVER I1-800.347.2683) For assistance, see reverse side. Transactions SO fraud liability Guarantee Use your Discover Card with confidence. Trans. Post Date Date Payments and Credits Apr 30 Apr 30 INTERNAL CHARGE-OFF $ •12,434.78 'Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCEMAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 5 days Purchases $0 0.07737% 28.24% V 28.24% $0 none Cash Advances $0 0.07737% 28.24% V 28.24% $0 $0 The rates that apply To your Account are either Fixed (FI or they may vary (Vi as noted above. Exhibit "A" ATTORNEY: STOCK ACCOUNT NUMBER: 6011002828523589 BALANCE: $12434.78 CARDMEMBER (S): NATALIE Y JACKSON STATE OF OHIO COUNTY OF FRANKLIN Rex Payne, personally appeared before me, this day and after being duly sworn, according to law, upon his/her oath and says: I am a Legal Placement Account Manager for DFS SERVICES LLC., the servicing agent of DISCOVER BANK, an FDIC insured Delaware State Bank. THAT this affidavit is made on the basis of my personal knowledge and in support of Plaintiffls suit on account against the Debtor(s) THAT, in my capacity as Legal Placement Account Manager, I have control over and access to records regarding the Discover Card Account of the above referenced Debtor(s), further, that I have personally inspected said Account and statements regarding the balance due on said account. DFS SERVICES, LLC. maintains these records in the ordinary course of business. THAT the annexed statement of account is a true and correct statement of what is now due and owing Discover Bank on the account, and exhibit A is a copy of the Cardmember Agreement between Discover Bank and the above referenced Debtor(s). The Cardmember Agreement governs the terms and conditions of the relationship between Discover Bank and the Debtor(s) in connection with the account. Based on my review of the account records, to the best of my knowledge and belief the above referenced Debtor(s) is not engaged in the military service of the United States and is a resident of the State and of the Country in which this action has been filed. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Affiant MIRANDAROBERTSON Notary t~ubGc, Stye of Ohio ~~~ July 27, 2011 Exhibit "B" Sworn and Subscribed before me, This day of Tuesday, July 17, 2007. Request for Military Status Page 1'of 2 ' Department of Defense Manpower Data Center AUG-27-2007 07:05:23 ~, Military Status Report Pursuant to the Servicemembers Civil Relief Act Last Name First/Middle Begin Date Active Duty Status Service/Agency JACKSON Natalie Y Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA maybe invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink mil/fad/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.miUscra/owa/scra.prc_Select 8/27/2007 f^7 N U :~ -a ~t.r - ,.._~ T , , c.IT - '!, V , ~ i ~ ~ ( ~. ~ 1 r,~ + _ ~ _ ~ _~ , ~, SHERIFF'S RETURN - REGULAR CASE NO: 2007-05756 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK ET AL VS JACKSON NATALIE Y MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE JACKSON NATALIE Y the DEFENDANT at 1145:00 HOURS, on the 8th day of October 2007 at 615 MT ROCK ROAD CARLISLE, PA 17015 BARRY JACKSON, HUSBAND was served upon by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. 18.00 10.56 .00 10.00 .00 38.56 Sheriff's Costs: Docketing Service Affidavit Surcharge C~,,., - ~ Jo, ~ f ~ ~ Sworn and Subscibed to before me this of So Answers: ~a~.~"''...~ R. Thomas Kline 10/09/2007 STOCK & GRIMES By. Deputy Sheriff A.D. day STOCK & GRIMES, LLP BY: Edward Stock, Esquire I.D. ##13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 DISCOVER DISCOVER DISCOVER LLC P.O. Box Dover, D] BANK, ISSUER OF CARD BY ITS AGENT FINANCIAL SERVICES, 6011 19903-6011 Plaintiff vs. NATALIE Y. JACKSON 615 Mt. Rock Road Carlisle, PA 17015 Defendant (s ) Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 2007-5756 PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above captioned case DATE : / o? O iscontinued. RE ~~ ~ _' c~ ~, ~ ~ r-t ` f.~..j i ~ a ~ ~ 9 .. ._ ~' ~1