HomeMy WebLinkAbout08-5088
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
DAN CAHAN
Defendant
No : D$ - S-m
C'??.C-
"-
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06861146 C A Pit ABR
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
DAN CAHAN
Defendant
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims 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
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff, is a corporation with offices at 6500 New Albany Rd,
New Albany, OH 43054.
2. Defendant is adult individual(s) residing at the address listed
below:
DAN CAHAN
304 N. FAYETTE ST., ##102
WALNUT BOTTOM, PA 17266
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXXXXXX0830 . A copy of
Plaintiff's Statement of Account s attached hereto, marked as Exhibit
"A" and made a part hereof.
4. Defendant made use of said credit card and currently has a balance
due and owing to Plaintiff, as of July 23, 2008 , in the amount of
$4795.24 .
5. Defendant is in default by failing to make payments when due.
6. Plaintiff avers that the Agreement between the parties provides
that Defendant will pay Plaintiff's attorneys' fees.
7. Plaintiff avers that such attorneys' fees will amount to $500.00 .
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due to Plaintiff.
Wherefore, the Plaintiff prays for Judgment in its favor and
against Defendant , DAN CAHAN INDIVIDUALLY , in the amount of
$4795.24 with interest at the legal rate of 6.000W per annum from date
of judgment plus attorneys' fees of $500.00 , and costs.
James C/ armbrodt,42524
WELT W INBERG & REIS CO., L.P.A.
436 S ent Avenue, Suite 1400
Pitts urgh PA 15219
(412 434- 955
FAX: 412- 38-7130
068 1146 C A Pit ABR
This law firm is a debt collector atte*tdig to collect this debt for
our client and any information obtained ill be used for that purpose.
I tnter Amount Enclosed Below
Payment Due Date $i L,
DUE IMMEDIATELY
08 SDSN6A01 0006300
DAN CAHAN Will your payment get to us on time? Pay
PO BOX 111 your bill online and your payment can be
WALNUT BOTTOM PA 17266-0111 made to your account on the some day. Visit
Discovercord.com/payments today.
PO BOX 15251 lllr,rllr,rlln?lnlurl,ll
Address, e-mail or telephone change? Print change inspace WILMINGTON DE 19886-5251
above, or go to Discovercard.com.Print your e-mail adessto I"'l?lilulul?Inlnllu?l?lu?I?l???Iuul????lunll??l??i
receive important Account information and special offers.
000001986458363274354047952400000000479524
Discover More Card Account Summary
Closing Dane: May 8, 2008
A
ccount number ending in
Payment Due Dat 0830
e June 7, 2008
Minimum Payment Due $4,795.24
Credit limit $3,500.00
Credit Available $0.00
Cash Credit Limit $0.00
Cash Credit Available $0.00
EXHIBIT
page 1 of I
Previous Balance
$4
795
24
Payments And Credits ,
.
.
Purchases 0.00
Cash Advances + 0.00
Balance Transfers + 0.00
Finance Charges + 0.00
New Balance + 000
. $4,795.24
-- Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 000
C"ashbackBonus?t Anniversary -- - - - - - - - - - - - - - - - - - - - -AAvat ak ?? once - - - - ` $ 0.00
Date: April 8
How Can We Help You? 1 • Visit Discover.corn to pay your bbl for no cost, view yo r
It's your choice - 3 ways to help 2. latest 1-800-DISC VER 47-2683) fo,?f st ;a y self servviice °r°
Please have your Discover Card available. options or to speak with a Customer Service Account Manager
For TDD )assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943,
Soh Lake City, UT 8,4130
Transactions $0 Fraud Liability Guarantee use your Discover Card with confidence.
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
Fi
Ch
nance
arge Summary
Aver a
age
Daily
Daily
Periodic Nominal
ANNUAL
NiAGE
ANNUAL
Periodic Transaction
I.
Balances Rates RA•ES RAATESNTAGE FIB pGE
current billing period: 8 days S
Purchases $0
Cash Advances
$0 0.07942% 28.99% F
28.99%
$0
!previous billing period: 20 days
0.07942%
28.99% F
28.99%
$0 none
$0
Purchases $0 0.07942% 28.99% F 28.99%
The rates that apply to your Account are either fixed (F) or the
y may vary (V) as n oted above.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to
unsworn falsifications to authorities, that he/she is Robert Adkins
(Name)
Accounts Manager of DFS Services LLC , plaintiff herein, that
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint
in Civil Action are true and correct to the best of his/her knowledge, information and belief.
Signature)
WWR # 6861146
DAN CAHAN
6011002250370830
r p7
? C-`7 ' t
f
^
V r
0
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05088 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
CAHAN DAN
TIMOTHY R BLACK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
rnunu nam the
DEFENDANT , at 0018:30 HOURS, on the 15th day of September, 2008
at 57 EAST MAIN STREET
WALNUT BOTTOM, PA 17266
DAN CAHAN
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Ib'
by handing to
DEFENDANT
So Answers:
18.00
14.00
* 00
10.00 R. Thomas Kline
.00
42.00 09/16/2008
WELTMAN WEINBERG & REIS
Sworn and Subscibed to
before me this
of
By:
day 'Deputy Sheriff
A. D.
8. ,
IN THE COMMON PLEAS COURT OF THE STATE OF PENNSYLVANIA
IN AND FOR CUMBERLAND COUNTY
DISCOVER BANK
V. Case Number: 08-5088
DAN CAHAN
ANSWER OF DEFENDANT
Defendant Dan Cahan answers the Complaint of Discover Bank as follows:
1. The Defendant lacks sufficient information to either admit or deny the
allegations of Paragraph 1 of the Complaint.
2. The Defendant denies the allegations of Paragraph 2 of the Complaint.
Defendant's correct address is PO Box 111, 57 E. Main St., Walnut Bottom, Pa., 17266.
3. The Defendant admits the allegations of Paragraph 3 of the Complaint.
4. The Defendant denies the allegations of Paragraph 4 of the Complaint.
Defendant denies the balance due and demands a strict accounting of all charges and
credits to the account. Plaintiff s exhibit is merely a statement and not an accounting.
5. The Defendant denies the allegations of Paragraph 5 of the Complaint. He is
working with a credit counselor in an attempt to resolve this account.
6. The Defendant denies the allegations of Paragraph 6 of the Complaint.
Defendant does not recall receiving or signing an agreement as to this account. He
demands proof of a signed agreement.
7. The Defendant denies the allegations of Paragraph 7 of the Complaint.
Defendant does not recall receiving or signing an agreement as to this account. He
demands proof of a signed agreement which would authorize any attorney's fee.
8. The Defendant denies the allegations of Paragraph 8 of the Complaint. He is
working with a credit counselor in an attempt to resolve this account.
Further answering:
9. Since July, 2008 Defendant has been unable to pay the debt for the following
reasons: Unexpected increase in housing expenses. Defendant cannot pay basic living
This document was prepared by or with the assistance of an attorney employed by The Legal Advice Line Consortium consisting of
Legal Advice Line, LLC, Persels & Associates, LLC, and Consumer Law Associates, LLC; 866442-5669.
F ?
expenses and keep up with creditor payments. Has tried to cut expenses and live on a
budget with minimal success.
10. Defendant has repeatedly offered to restructure payments on the debt which
Defendant can afford but the Plaintiff has failed or refused to accept such payments.
11. Defendant is willing to make payment arrangements with the Plaintiff.
VERIFICATION
The Defendant verifies that the statements made herein are true and
correct based upon his knowledge, information and belief. The statements are made
subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to
authorities.
G?
- J4 AI%n cahan
PO Box 111
57 E. Main St.
Walnut Bottom, Pennsylvania 17266
215-595-7164
CERTIFICATE OF SERVICE
The Defendant(s) HEREBY CERTIFY that on this - day of
20` a copy of the foregoing pleading was mailed, first-class, postage pre-paid to:
James C. Warmrodt, Esq,
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, Pennsylvania 15219
412-434-7955
Attorney for Plaintiff
Dan Cahan
This document was prepared by or with the assistance of an attorney employed by The Legal Advice Line Consortium consisting of
Legal Advice Line, LLC, Persels & Associates, LLC, and Consumer Law Associates, LLC; 866-442,669.
:?;
i
;,
??. ryas.
"?
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
?1SCUV?? ?C?-??
(Plaintiff)
Vs.
-'7DQn Ca-"an
(Defendant)
No. 5 C g" Civil nd'0a 9
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
demurrer to complaint, etc.):
2. Identify counsel who will argue case:
U? yJIJC•nr e?
(a) for plaintiff : ` cum n
Address:
Weltman, Weinberg & Reis Co.
1400 Koppers Bldg.
436 7th Ave.
Pittsburgh, PA 15219
(412) 434-7955
(b) for defendant: -P ro S? U2-
Address: 3a LI N . ?, 170 U Co
WaAnv-+ k-2DC>tA&0-`
3. I will notify all parties in writing within two days that this case bas
been listed for argument.
4. Argument Court Date : ®c?? r M 1 9009
rr- - -
CA/ AL
FILED ' w"1- kt?t-
GF THE P r'l "! TAf?Y
2009 AUGG 18 P1", 1 *- '± ;
C?1?J1?. j?' Ih E1'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK,
Plaintiff,
Vs.
DAN CAHAN,
Defendant.
Case No.: 08-5088-CIVIL TERM
MOTION FOR SUMMARY JUDGMENT
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Benjamin R. Bibler,Esquire
PA ID# 93598
Weltman,Weinberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK,
Plaintiff, Case No.: 08-5088-CIVIL TERM
VS. MOTION FOR SUMMARY JUDGMENT
DAN CAHAN,
Defendant.
MOTION FOR SUMMARY JUDGMENT
AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co.,
L.P.A., and hereby files this Motion for Summary Judgment against the Defendant. In support thereof,
Plaintiff avers as follows:
1. Plaintiff filed a Complaint against Defendant seeking judgment in the amount of
$4,795.24 with interest at the interest rate of 6.00% per annum from the date of judgment, plus attorney's
fees, and costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a
part hereof.
2. Attached to the Complaint was Verification from an authorized representative of Plaintiff
verifying the accuracy of the amount sought. See Exhibit "A".
3. Defendant filed an Answer to Plaintiff's Complaint. A true and correct copy of the
Answer is attached hereto as Exhibit "B" and made a part hereof.
4. On or around June 2, 2009, Plaintiff served upon Defendant a set of requests for
admissions and requests for production of documents. A true and correct copy of the same is attached
hereto as Exhibit "C" and made a part hereof.
5. No response to the discovery demands has been received from the Defendant.
6. The requests for admissions are now deemed admitted under Pennsylvania Rule of Civil
Procedure 4014(b). Thus Defendant has admitted that he has made no payment on the credit card since
September 16, 2007; that he applied for the credit card; that the statements attached to Plaintiffs
Discovery Request correctly identify the payments, charges, and balances on the account; that he has not
submitted any written disputes as to billing inaccuracies; and that $4,795.24 is a correct and accurate
balance on the credit card account.
7. By way of his Answer, the documents attached to this Motion, and the Requests for
Admissions, deemed admitted under Pa.R.C.P. 4014(b), the Defendant has admitted all facts material to
this matter and verified the amount owed.
8. There are no meritorious defenses against this action and Plaintiff is entitled to
summary judgment as a matter of Law against defendant.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant summary
judgment in favor of Plaintiff and against Defendant for $4,795.24 with interest at the legal
interest rate of 6.00% per annum from the date of judgment, plus attorney's fees of $500.00, and
costs.
Respectfully Submitted:
By:
BenjV95 le •, squire
PA Wel, erg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
DAN CAHAN
Defendant
No.
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06861146 C A Pit ABR
EXHIBIT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
DAN CAHAN
Defendant
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims 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
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff, is a corporation with offices at 6500 New Albany Rd,
New Albany, OH 43054.
2. Defendant is adult individual(s) residing at the address listed
below:
DAN CAHAN
304 N. FAYETTE ST., #102
WALNUT BOTTOM, PA 17266
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXXXXXX0830 . A copy of
Plaintiff's Statement of Account s attached hereto, marked as Exhibit
"A" and made a part hereof.
4. Defendant made use of said credit card and currently has a balance
due and owing to Plaintiff, as of July 23, 2008 , in the amount of
$4795.24 .
5. Defendant is in default by failing to make payments when due.
6. Plaintiff avers that the Agreement between the parties provides
that Defendant will pay Plaintiff's attorneys' fees.
7. Plaintiff avers that such attorneys' fees will amount to $500.00 .
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due to Plaintiff.
Wherefore, the Plaintiff prays for Judgment in its favor and
against Defendant , DAN CAHAN INDIVIDUALLY , in the amount of
$4795.24 with interest at the legal rate of 6.000. per annum from date
of judgment plus attorneys' fees of $500.00 , and costs.
-
James C armbrodt,42524
WELT W INBERG & REIS CO., L.P.A.
436 S ent Avenue, Suite 1400
Pitts urgh PA 15219
(412 434- 955
FAX: 412- 38-7130
068 1146 C A Pit ABR
This law firm is a debt collector atteptAg to collect this debt for
our client and any information obtaine ill be used for that purpose.
08 SDSN6A01 0006300
DAN CAHAN
PO BOX 111
WALNUT BOTTOM PA
"" _? wer Amour` `nclosed Below
Payment Due Date
DUE IMMEDIATELY i
Will your payment get to us on time? Pay
Your bill online and your payment can be
17266-0111 made to your account on the same day. Visit
Discovercard.com/payments today.
PO BOX 15251 ((t1ul(rull111r(„1111[ill
Address, e-mail or telephone change? Print change in space WILMINGTON DE 19886-5251
above, or go to Discovercard.com.Print your e-mailaddressto
receive important Account information and special offers.
000001986458363274354047952400000000479524
Discover More Card Account Summary
Closinq Date:
Account number ending in 0830
Payment Due Date June 7, 2008
Minimum Payment Due $4,795.24
Credit Limit $3,500.00
Credit Available $0.00
Cash Credit Limit $0.00
Cash Credit Available $0.00
EXHIBIT
May 8, 2008 page 1 of 1
Previous Balance $4
795
24
Payments And Credits ,
.
Purchases 0 24
Cash Advances + 0.00
Balance Transfers + 0.00
Finance Charges + 0.00
New Balance + 000
+
$4,795.24
- Cashback Bonus® O
i
- pen
ng Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned
+ 0.00
Cdshbock-BoriusO Anniversary -- ------- -----------
Casback vailable to Rede aemlant - - - - - - - - $ 0.00
-- A
$
Date: April8 - 0.00
How Can We Help You?
It's your choice - 3 wa
s to hel I • Visit Discover.com to pay your 1611 for no cost, view our
latest Account information, earn and redeem rewards and more
2
C
ll
y
p
Please have your Discover Card available. .
a
1-800-DISCOVER (347-2683) for fast, easy self service
options or to speak with a Customer Service Account Mana
For TDD (assistance for hearing impaired) see reverse side ger
84 3' Write us at y, UT Card, PO Box 30943,
Salt Lake City, UT
130
Transactions $0 Fraud Liability Guarantee U
Information For You se your Discover Card with confidence.
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
Finance Charge Summary
Average
Daily
Daily
Periodic Nominal
ANNUAL
PERCENTAGE
ANNUAL
Periodic
Transaction
Fee
Balances Rates . RATES PE
PERCENTAGE C
A
ES
current billing period: 8 days CHARGES I
RGR
Purchases $0
Cash Advances $0 0.07942% 28.99% F 28.99%
$0
none
previous billing period: 20 days 0.07942% 28.99% F 2
8.99% $0 $0
Purchases $0 0.07942% 28.99% F
28.99%
$0
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. none
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to
unswom falsifications to authorities, that he/she is Robert Adkins
(Name)
Accounts Manger of DFS Services LLC ; plaintiff herein, that
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint
in Civil Action are true and correct to the best of his/her knowledge, information and belief.
r
(Signature)
WWR # 6861146
DAN CAHAN
6011002250370830
IN THE COMMON PLEAS COURT OF THE STATE OF PENNSYLVANIA
IN AND FOR CUMBERLAND COUNTY
DISCOVER BANK
V. Case Number: 08-5088
DAN CAHAN
ANSWER OF DEFENDANT
Defendant Dan Cahan answers the Complaint of Discover Bank as follows:
1. The Defendant lacks sufficient information to either admit or deny the
allegations of Paragraph 1 of the Complaint.
2. The Defendant denies the allegations of Paragraph 2 of the Complaint.
Defendant's correct address is PO Box 111, 57 E. Main St., Walnut Bottom, Pa., 17266.
3. The Defendant admits the allegations of Paragraph 3 of the Complaint.
4. The Defendant denies the allegations of Paragraph 4 of the Complaint.
Defendant denies the balance due and demands a strict accounting of all charges and
credits to the account. Plaintiff's exhibit is merely a statement and not an accounting.
5. The Defendant denies the allegations of Paragraph 5 of the Complaint. He is
working with a credit counselor in an attempt to resolve this account.
6. The Defendant denies the allegations of Paragraph 6 of the Complaint.
Defendant does not recall receiving or signing an agreement as to this account. He
demands proof of a signed agreement.
7. The Defendant denies the allegations of Paragraph 7 of the Complaint.
Defendant does not recall receiving or signing an agreement as to this account. He
demands proof of a signed agreement which would authorize any attorney's fee.
8. The Defendant denies the allegations of Paragraph 8 of the Complaint. He is
working with a credit counselor in an attempt to resolve this account.
Further answering:
ollowing
9. Since July, 2008 Defendant has been unable to pay the debt for tXxi
reasons: Unexpected increase in housing expenses. Defendant cannot a g P Y BIT
This document was prepared by or with the assistance of an attorney employed by The Legal Advice Line Consortium consisting of
Legal Advice Line, LLC, Persels & Associates, LLC, and Consumer Law Associates, LLC; 866-4425669.
expenses and keep up with creditor payments. Has tried to cut expenses and live on a
budget with minimal success.
10. Defendant has repeatedly offered to restructure payments on the debt which
Defendant can afford but the Plaintiff has failed or refused to accept such payments.
11. Defendant is willing to make payment arrangements with the Plaintiff.
VERIFICATION
The Defendant verifies that the statements made herein are true and
correct based upon his knowledge, information and belief. The statements are made
subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to
authorities.
Dan Cahan
PO Box 111
57 E. Main St.
Walnut Bottom, Pennsylvania 17266
215-595-7164
CERTIFICATE OF SERVICE
The Defendant(s) HEREBY CERTIFY that on this 1 day of f1rt)'??:b '; ,
20,)(4a copy of the foregoing pleading was mailed, first-class, postage pre-paid to:
James C. Warmrodt, Esq,
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, Pennsylvania 15219
412-434-7955
Attorney for Plaintiff
Dan Cahan
This document was prepared by or with the assistance of an attorney employed by The Legal Advice Line Consortium consisting of
Legal Advice Line, LLC, Persels & Associates, LLC, and Consumer Law Associates, LLC; 8664425669.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
DISCOVER BANK,
Plaintiff,
V. NO.: 08-5088 CIVIL TERM
DAN CAI-IAN
Defendant.
PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS AND REQUEST FOR
PRODUCTION OF DOCUMENTS
Plaintiff demands that the defendants answer and respond to the following Request for
Production of Documents under oath pursuant to the Pennsylvania Rules of Civil Procedure
within 30 days from the date of service hereof.
Plaintiff also demands that defendants answer and respond to the following Request for
Admissions pursuant to Pa. Rules of Civil Procedure 4014.
You are requested to admit the truth of each of the statements of fact hereinafter stated. You are
instructed that:
1. These requests are made under Pennsylvania Rules of Civil Procedure 4001, et
seq., and each of these matters of which an admission is requested shall be deemed admitted
unless your sworn statement in compliance with such Rules is timely made.
2. If you do not admit each of such statements, you must specifically deny each one
not admitted or set forth in detail the reasons why you cannot truthfully either admit or deny each
such matter.
3_ Your answer, signed and properly verified, must be delivered to the undersigned
attorney of record for the Plaintiff within thirty (30) days after delivery hereof.
4. If you fail or refuse to admit the truth of any such statement of fact and the
Plaintiff thereafter proves the truth thereof, you may be required to pay the reasonable expenses
incurred in making such proof, including attorneys' fees, witness expenses, etc.
5. If, in response to any of the following statements of fact, it is your position that
the statement is true in part or as to some items, but not true in full or as to all items, then answer
separately as to each part or item.
6. If you have been sued in more than one capacity or if your answers would be
different if answered in any different capacity, such as partner, agent, corporate officer or director
EXHIBIT
or the like, then you are requested to answer separately in each such capacity. Failure to do so
constitutes an admission in any such capacity.
7. In these Requests for Admissions:
A. The word "person(s)" means all entities, and, without limiting the
generality of the foregoing, includes natural persons, joint owners, associations, companies,
partnerships, joint ventures, trusts, and estates;
B. The word "document(s)" means all written, printed, recorded, graphic, or
photographic matter, or, sound reproductions, however produced or reproduced, pertaining to any
manner to the subject matter indicated;
C. The words "identity" "identify", "identification", when used with
respect to a person(s) means to state the full name and present or last known address and business
address of such person(s) and, if an actual person, his present or last known job title, and the
name and address of his present or last known employers;
D. The words "identity" "identify" "identification", when used with respect
to a date, subject matter, name(s) or person(s) that wrote, signed initialed, dictated or otherwise
participated in the creation of the same, the name(s) of the addressee or addressees if any and the
name(s) and address(es) of each person who have possession, custody, and control of said
document(s). If any such document was, but is no longer in your possession, custody, or control,
or in existence, state the date and manner of its disposition; and
E. The word "identify", when used with respect to an act (including an
alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act"), means
to (1) describe the substance of the event or events constituting such an act, and to state the date
when such act occurred; (2) identify each and every person(s) participating in such an act; (3)
identify all other person(s) (if any) present when such act occurred; (4) state whether any minutes,
notes, memoranda, or other record of such act was made; (5) state whether such record now
exists; and (6) identify the person(s) presently having possession, custody or control of such
record.
8. Unless otherwise indicated, all Requests herein relate to those certain events,
persons, and period of time more fully described in the pleading in this case.
These requests are of a continuous nature.
These Requests for Production of Documents shall be deemed continuing so as to require
supplemental answers and documents if any information of documents are acquired subsequent to
the filing of responses hereto, which information or documents would have been included in the
answers and documents produced had it been known or available at the time the answers and the
documents provided pursuant hereto were produced. Defendants shall supply such information
and documents by supplemental answers and production of documents as soon as such
information becomes known or available and in all events, prior to trial of this action.
If objection is made to any requests for production of documents, it is demanded that the
requests for which there is no objection be answered and furnished within the aforesaid period.
All documents identified in response hereto shall be organized and labeled to correspond
with the request to which it pertains. For all documents produced, list the individual and his or
her job title and department from whose files it was produced and the current custodian of said
document.
If a document called for is believed to exist or is known to exist, but is in the possession,
custody or control of another person or party, the existence of the document, the identity of the
possessor, custodian and one in control of such documents shall be provided along with any
applicable common description or citation utilized by the publisher, possessor, custodian or
disseminator of such document.
If any document called for by this request is withheld on the basis of any claim of
privilege or any similar claim, identify that document as follows: author; addressee; indicated or
blind copies, date, subject matter; number of pages; attachments or appendices; all persons to
whom distributed, shown or explained; present custodian; and nature of the privilege or similar
claim asserted.
REQUEST FOR PRODUCTION OF DOCUMENTS l:
Produce any and all documents evidencing proof of all payments on the subject credit
card referenced in the Complaint, including, but not limited to, cancelled checks, receipts,
coupons, statements, accountings, memoranda, invoices, financial statements, accounting entries,
diaries, charts, lists, phone records, data compilations etc.
REQUEST FOR PRODUCTION OF DOCUMENTS 2:
Produce any and all documents you intend to introduce and/or provide testimony on as
evidence at the time of trial.
REQUEST FOR ADMISSION NO. l:
Defendant applied for the credit card referenced in Plaintiff s Complaint.
Admitted
Denied
If the answer to Request for Admissions No. 1 is "denied", then supply specific written
documentation supporting the denial.
REQUEST FOR ADMISSION NO. 2:
The attached monthly statements, from August 10 2007 through May 8 2008, correctly identify
the payments, charges, and balances on the account.
Admitted
Denied
If the answer to Request for Admissions No. 2 is "denied", then supply copies of canceled
checks, both front and back, and/or if not available, specific written documentation supporting the
denial.
REQUEST FOR ADMISSION NO. 3:
The last payment on the account was made on September 16 2007.
Admitted
Denied
If the answer to Request for Admissions No. 3 is "denied", then supply specific written
documentation supporting the denial.
REQUEST FOR ADMISSION NO. 4:
Defendant has not submitted any written dispute as to billing inaccuracy concerning the credit
card in question.
Admitted
Denied
If the answer to the Request for Admissions No. 4 is "denied", then supply copies of specific
written disputes as to any billing inaccuracies.
REQUEST FOR ADMISSION NO. 5:
$4795.24 is a correct and accurate current balance of the credit card account in question.
Admitted
Denied
If the answer to Request for Admissions No. 5 is "denied", then supply specific written
documentation supporting the denial.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED SHALL BE USED FOR THAT PURPOSE.
Pen m R. Bklei esquire
P . #93598
LTMAN, WEINBERG & REIS
CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-79555
WWR: 6861146
DEFENDANT'S VERIFICATION
I, , (please print) under penalty of perjury and
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to
authorities verify that the foregoing Responses are true and correct to the best of my
knowledge, information and belief.
Date
Signature
LJIJLVV CK $1,910.21 $39.00 i Enter Amount Enclosed Below
CARD
Payment Due Date
September 9, 2007 please make check payable to Discover Card or
pay online @ Discovercard.com.
kr?-
i
10 SDSN6A01 0001823
CAHAN, DAN / C- I P' ,Will your payment get to us on time? Pay
PO BOX 111 your bill online and your payment can be
made to your account on the some day. Visit
WALNUT BOTTOM PA 17266-0111 Discover.com/payments today.
PO BOX 71084 Ill irrllrrrrrillllrrrlrlril
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354019102100000000003900
Discover More Card Account Summary
Closing Date: August 10, 2007 page 1 of 2
Account number ending in 0830
Payment Due Date September 9
Minimum Payment Due $39.00
Credit Limit $3,500.00
Credit Available $1,567.00
Cash Credit Limit $1,800.00
Cash Credit Available $1,567.00
Previous Balance $0.00
2007 Payments And Credits 0.00
Purchases + 11910.21
Cash Advances + 0.00
Balance Transfers + 0.00
Finance Charges + 0.00
New Balance = $1,910.21
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
'Cashback Bonus®
Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 5.80
Cashback Bonus Balance $ 5.80
Cashback Bonuse Since-Anniver'seiy Date Available-to Redeem - - - $- -0.00 - - -
of April 10: $5.80
Cashback Bonus(R) is America's #1 Cash
Rewards Programl Full 5% Cashback Bonus
on Get More purchases in popular categories
'throughout the year and up to 1 % Cashback
Bonus on all your other purchases.
How Can We Help You?
It's your choice - 3 ways to help
Please have your Discover Card available.
For TDD (assistance for hearing impaired) see reverse side
1. Visit Discover.com to pay your bill for no cost, view your
latest Account information, earn and redeem rewards and more
2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
options or to speak with a Customer Service Account Manager
3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence
Trans. Post
Date Date
Merchandise/Retail Jul 29 Jul 29 PETSMART 00015560 CHAMBERSBURG PA $ 13.69
Jul 29 Jul 29 TARGET CHAMBERSBURG PA 184.57
-Jul 29 - - Jul 29 --WAL-MART-SC - #5358 SHIPPENSBURG PA-- ---11.29--
Jul 29 Jul 29 WAL-MART SC - #5358 SHIPPENSBURG PA 90.42
Jul 30 Jul 30 EB GAMES #5605 SHIPPENSBURG PA 77.34
Aug 3 Aug 3 WAL-MART SC - #1019 CANON CITY CO 21.23
Restaurants Jul 27 Jul 27 SUBWAY #34296 SHIPPENSBURG PA 13.33
Jul 27 Jul 27 FRANKS TASTE OF ITALY MONT ALTO PA 18.50
Jul 29 Jul 29 BURGER KING #11780 Q07 CHAMBERSBURG PA 4.45
Jul 30 Jul 30 NATHANS FAMOUS ATLANTA GA 7.28
Aug 4 Aug 4 ELEPHANT BAR # 227 COLORADO SPRICO 22.82
Aug 4 Aug ,4 ELEPHANT BAR # 227 COLORADO SPRICO 23.00
Aug 4 Aug 4 DOMINO'S PIZZA #06275 CANON CITY CO 19.47
Aug 6 Aug 6 TACO BELL #03671435525 CANON CITY CO 5.51
Aug 7 Aug 7 PHANTOM CANYON BREWING C COLORADO SP CO 19.00
Gasoline Jul 29 Jul 29 EXXONMOBIL SHIPPENSBURG PA 20.03
Jul 29 Jul 29 RUTTER'S FARM STORE #31 SHIPPENBURG PA 33.32
Manage your budget, track your spending and avoid fees with FREE timely e-mail reminders. Learn more about e-mail
l ....a _fd_ a _1;_ ___f r n,....e. .a -
CARD
I - -..-l, --- I Account number ending in 0830
----0nghlQr
Have a question? Talk to us
There's no telling when you might have a question about your Discover" Card
account. Which is why we're here 24 hours a day, 7 days a week. Perhaps
best of all, you'll be connected to one of our friendly, knowledgeable
Customer Service Representatives in less than a minute. Real answers from
real people. It's just one of the ways we put you first.
Call us at 1-800-DISCOVER (1-800-347-2683)
02007 Discover Bank, Member FDIC
Closing Date: August 10, 2007 page 2 of 2
Gasoline Jul 30 Jul 30 EXXONMOBIL SHIPPENSBURG PA 5
91
Jul 31 Jul 31 LOAF N JUG #36 COLORADO SPGSCO .
4
89
Aug 3 Aug 3 LOAF N JUG #36 COLORADO SPGSCO .
3
99
Aug 3 Aug 3 LOAF N JUG #36 COLORADO SPGSCO .
46
51
Aug 6 Aug 6 SHELL 21957441058807 PENROSE CO .
4.79
Travel/Entertainment Jul 30 Jul 30 BLOCKBUSTER VIDEO #42275 SHIPPENSBURG PA 25
75
Aug 7 Aug 7 ORB*NXBTFA WWWORBITZCOM IL .
143.89
Services Jul 30 Jul 30 VZWRLSS MYACCTVE 1-800.922-020CA 410
15
Jul 30 Jul 30 PENELEC/METED/JCPL 800.646.0400 OH .
259.54
1883536122
Jul 30 Jul 30 FEES 214.750-2700 TX 3.95
3883536122
Jul 30 Jul 30 ALLSTATE *PAYMENT 800-255-7828 IL 319.32
3320015,420070730
Aug 3 Aug 3 ECHO CANYON RIVER EXPEDI CANON CITY CO 96.27
Information For You
Discover Financial Services is proud to support the Juvenile Diabetes Research Foundation's Walk to Cure Diabetes.
Consider donating your Cashback Bonus(R) to JDRF and you can help Fund research to find a cure. To further your donation
Discover(R) Card will add an additional 20%. Visit Discovercard.com
Finance Charge Summary
Average
Daily Nominal
ANNUAL
ANNUAL
Periodic Transaction
F
Daily
Balances
Periodic
Rates
PERCENTAGE
RATES
PERCENTAGE
FINANCE ee
FINANCE
RATES CHARGES CHARGES
current billing period: 31 days
Purchases $0 0.05477% 19.99% V 19.99% $0 n
Cash Advances $0
0.06299%
22.99% F
22.99%
$0 one
$0
previous billing period: 30 days
Purchases $0 0.05477% 19.99% V 19.99% $0 none
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
Questions? Manage your account at Discover.com or
rrrll 1-Ann_nlcrnvro tl-Rnn-Zn7_0,cV?1
VIJ<.V CK
CARD
10 SDSN6A01 0001824
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA
$3,591.44 I $138.00 1 Enter Amount Enclosed Below
Payment Due Date $ 1- 71
October 9, 2007 Please make check payable to Discover Card.
You are overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
$91.44.
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
17266-0111 Discover.com/payments today.
PO BOX 71084 11111r??rrrirr????rriIrIrrI
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354035914400000000013800
Discover More Card Account Summary
Closing Date: September 10, 2007 page 1 of 2
Account number ending in 0830 Previous Balance $1,910.21
Payment Due Date October 9, 2007 Payments And Credits 0.00
Minimum Payment Due $138.00 Purchases + 1,344.29
Credit Limit $3,500.00 Cash Advances + 233.50
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $1,800.00 finance Charges + 103.44
Cash Credit Available $0.00 New Balance = _
$3,591.44
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
Cashback Bo nus® Opening Cashback Bonus Balance $ 5.80
New Cashback Bonus Earned + 6.50
Cashback Bonus Balance $ 12.30
Cashback B6n6i0Since Annivefsary Date - - - - - - - - - - - Available to Redeem $ - _0.00
- 0.00
of April 10: $12.30
How Can We Hel You?
p 1 • Visit Discover.com to pay your bill for no cost, view your
l
It's your choice - 3 ways to help atest Account information, earn and redeem rewards and more
2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
Please have your Discover Card available. options or to speak with a Customer Service Account Manager
For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 8,4130
Transactions $0 fraud Liability Guarantee Use your Discover Card with confidence.
Trans. Post
Date Date
Merchandise/Retail Aug 11 Aug 1 1 PARADIES-COLORADO SPRING COLORADO SPRICO $ 8.90
Aug 12 Aug 12 BARNES & NOBLE #269Q90 FAIRLESS HILLPA 43.40
Aug 14 Aug 14 STEVE & BARRY #144 PHILADELPHIA PA 116.90
Aug 15 Aug 15 WAL-MART SC - #5358 SHIPPENSBURG PA 55.81
Aug 16 Aug 16 WAL-MART SC - #5358 SHIPPENSBURG PA 24.32
Aug 16 Aug 16 WAL-MART SC - #5358 SHIPPENSBURG PA 29,98
Aug 18 Aug 18 WAL-MART SC - #5358 SHIPPENSBURG PA 86.58
Aug 20 Aug 20 WAL-MART SC - #5358 SHIPPENSBURG PA 37.69
-Aug 23- Aug 23 -WA-L-ivlAR-T-SC = #5358 SHIPPENSBURG-P-A - -50.80
-
Restaurants Aug 9 Aug 11 FAT BOYS PIZZA COLORADO SPRICO 17.30
Aug 11 Aug 1 1 HMSHOST-PA-TURNPK #063 BOWMANSIVLLE PA 7.83
Aug I 1 Aug 11 CREATIVE HOST COS AP COLORADO SPRICO 9.42
Aug 12 Aug 12 BURGER KING #10843 Q07 SHIPPENSBURG PA 5
06
Aug 13 Aug 13 GREAT AMERICAN DINER BEN BENSALEM PA .
39
50
Aug 24 Aug 24 FRANKS TASTE OF ITALY MONT ALTO PA .
18.20
Aug 28 Aug 28 PIZZA MAN SHIPPENSBURG PA 21
18
Aug 29 Aug 29 CHEF CHEN'S EXPRESS HARRISBURG PA .
6
40
Aug 29 Aug 29 ALFREDOS PIZZA SHIPPENSBURG PA .
10
17
Aug 29 Aug 29 WHITAKER CENTER-STARBUCK HARRISBURG PA .
4.40
Other/Miscellaneous Sep 10 Sep 10 OVERLIMIT FEE 39.00
Sep 10 Sep 10 LATE FEE 39.00
Gasoline Aug 8 Aug 11 LOAF N JUG #36 COLORADO SPGSCO 4.89
Aug 10 Aug 11 DIAMND 1 160 SHAMROCK COLORADO SPR CO 4.09
[>6J%w?. V CR
CARD
Account number ending in 0830
---Brighter I
Have a question? Talk to us.
There's no telling when you might have a question about your Discover" Card
account. Which is why we're here 24 hours a day, 7 days a week. Perhaps
best of all, you'll be connected to one of our friendly, knowledgeable
Customer Service Representatives in less than a minute, Real answers from
real people. It's just one of the ways we put you first.
Call us at 1-800-DISCOVER (1-800-347-2683).
02007 Discover Bank, Member FDIC
Closing Date: September 10, 2007 page 2 of 2
Gasoline Aug 12 Aug 12 LUKOIL 69709 LANGHORNE PA 36
01
Aug 15 Aug 15 RUTTER'S FARM STORE #31 SHIPPENBURG PA .
32
01
Aug 19 Aug 19 SHEETZ 0000 1859,498 CHAMBERSBURG PA .
34
85
Aug 23 Aug 23 SUNOCO SHIPPENSBURG PA .
33
77
Aug 23 Aug 23 SHEETZ 00000703,498 SHIPPENSBURG PA .
12
26
Aug 25 Aug 25 EXXONMOBIL SHIPPENSBURG PA .
4
38
Aug 25 Aug 25 TURKEY HILL #283 Q69 SHIPPENSBURG PA .
4
72
Aug 26 Aug 26 RUTTER'S FARM STORE #31 SHIPPENBURG PA .
48
91
Aug 27 Aug 27 EXXONMOBIL SHIPPENSBURG PA .
3
33
Aug 30 Aug 30 EXXONMOBIL SHIPPENSBURG PA .
3
80
Aug 30 Aug 30 EXXONMOBIL SHIPPENSBURG PA .
3
33
Aug 30 Aug 30 SHEETZ 00000703,498 SHIPPENSBURG PA .
475
Services Aug 17 Aug 17 HOLIDAY HAIR 91 16863573 SHIPPENSBURG PA 15
00
Aug 18 Aug 18 THE SENTINEL CARLISLE PA .
12
00
Aug 19 Aug 19 T-MOBILE # 7509 HAGERSTOWN MD .
393
72
Cash Advances Aug 13 Aug 13 PNC BANK ANDALUSIA PA .
100
00
Aug 13 Aug 13 CASH ADVANCE TRANS FEE FINANCE CHARGE .
5
00
Aug 15 Aug 15 COMMERCE BANK H CARLISLE PA .
82
00
Aug 15 Aug 15 CASH ADVANCE TRANS FEE FINANCE CHARGE .
5
00
Aug 30 Aug 30 M&T BANK SHIPPENSBURG PA .
10
00
Aug 30 Aug 30 CASH ADVANCE TRANS FEE FINANCE CHARGE .
5
00
Aug 30 Aug 30 CARDTRONIC MECHANICSBURGPA .
41
50
Aug 30 Aug 30 CASH ADVANCE TRANS FEE FINANCE CHARGE .
5.00
Supermarkets Aug 21 Aug 21 GIANT FOOD STORES #61 SHIPPENSBURG PA 20.63
Information For You
* * * ATTENTION * * * Your account is past due. Please pay the past due amount now, or contact us to make other
arrangements.
Finance Charge Summary
Balance Transfer offer for current billing period: Daily Periodic Rate: 0.07395% ; corresponding ANNUAL PERC ENTAGE
RATE: 26.99%. Rate is subject to the terms of the offer in
l
di
i
c
u
ng exp
ration.
Nominal
Average Daily ANNUAL
Dail
P
i
d
PER
ANNUAL
Periodic Transaction
Fee
y
er
o
ic
CENTAGE
Balances Rates RATES PERCENTAGE
RATES FINANCE FINANCE
current billing period: 31 days CHARGES CHARGES
Purchases $2922.28 0.07395% 26.99% F
Cash Advances
$199.80 0
07942% 28
99/ F 26.99%
$
none
.
.
previous billing period: 31 days 128.06% 4.92
$4.92 $20.00
Purchases $679.31 0.05477% 19.99% V 19.99% $11
53 n
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. . one
Questions? Manage your account at Discover.com or
r•r,ll 1.Ann_nlernvrD tl-nnnIA7-)AQ'Zt
VIJ%.,V*JV CK
CARD
10 SDSN6A01 0001825
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA
$3,722.42 $195.00 j Enter Amount Enclosed Below
Payment Due Date $ [-
November 9, 2007 Please make check payable to Discover Card.
You are overlimit. fay the sum of the monthly
minimum payment plus the overlimit amount of
$222.42.
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
17266-0111 Discover.com/payments today.
PO BOX 71084 Ill kill
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354037224 200000000019500
Discover More Card Account Summary
Closing Date: October 10, 2007 page 1 of 2
Account number ending in 0830 Previous Balance $3,591.44
Payment Due Date November 9, 2007 Payments And Credits 39.00
Minimum Payment Due $195.00 Purchases + 89.47
Credit Limit $3,500.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $1,800.00 Finance Charges + 80.51
Cash Credit Available $0.00 New Balance = $3,722.42
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
Cashback Bonus®
C6ihb4ckBoriusl& Since Anniversary Date
of April 10: $12.41
Opening Cashback Bonus Balance $ 12.30
New Cashback Bonus Earned + 0.11
Cashback Bonus Balance $ 12,41
Available-to- Redeem - - - - - . - - . - . - - $... - _ . 0.00
How Can We Help YOU? 1 • Visit Discoveacom to pay your bill for no cost, view your
N latest Account information, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
options or to speak with a Customer Service Account Manager
Please have your Discover Card available. 3. Write us at Discover Card, PO Box 30943,
For TDD (assistance for hearing impaired) see reverse side Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence
Trans. Post
Date Date
Payments and Credits Sep 16 Sep 16 PHONE PAYMENT - THANK YOU $ -39.00
Merchandise/Retail Sep 10 Sep 1 1 EBAY INC. SAN JOSE CA 11.47
Other/Miscellaneous Oct 10 Oct 10 OVERLIMIT FEE 39.00
Oct 10 Oct 10 LATE FEE 39.00
Information For You
While we are permitted-under theCardmember Agreement to Increase fhe-APRson your-Account-because-your payment - - - ---
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
* * * ATTENTION * * * Your account is post due. Please pay the past due amount now, or contact us to make other
arrangements.
Wish you could sort these purchases by amount, description or category? You can - register at Discovercard.com to view
,,,, ?r r,??r,-hr,we -h- - f- i,-, - 1 9 ..,H,. Ie,..., „,,,,e -4 n?..-...,e.?....J ?...,.1...
ulli%W' 49/ EM
CARD
Account number ending in 0830
y6tec_J
Have a question? Talk to us.
There's no telling when you might have a question about your Discover" Card
account. Which is why we're here 24 hours a day, 7 days a week. Perhaps
best of all, you'll be connected to one of our friendly, knowledgeable
Customer Service Representatives in less than a minute. Real answers from
real people. It's just one of the ways we put you first.
Call us at 1-800-DISCOVER (i-800-347-2683).
02007 Discover Bank, Member FDIC
Closing Date: October 10, 2007 page 2 of 2
Finance Charge Summary
Average
Dail
Daily
P
i
d Nominal
ANNUAL
PER
ANNUAL
Periodic Transaction
Fee
y
Balances er
o
ic
Rates CENTAGE
RATES PERCENTAGE
RATES FINANCE FINANCE
current billing period: 30 days CHARGES CHARGES
Purchases $3347.80
Cash Advances $261
42 0.07395% 26.99% F 26.99% $74.28 none
. 0.07942% 28.99% F 28.99% $6.23 $0
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
Questions? Manage your account at Discover.com or
rnll 1-A n1-nIC!'r''1vFD t1-A0n_1A7')Aa11
It; t:1%.17-.7 y CK,
C,,R-)
10 SDSN6A01 0001826
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA
$3,887.16 1 $297.00 ; Enter Amount Enclosed Below
Payment Due Date $ 1
December 9, 2007 Please make check payable to Discover Card.
You are overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
$387.16.
Will your payment get to us on lime? Pay
your bill online and your payment can be
made to your account on the some day. Visit
17266-0111 Discover. cam/payments today.
PO BOX 71084 ???rrr??rrrrrtill CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space 'i?Irl)rilrirlrl)rrrlr?lrlrrr(I?Ir?r)?rlr????l)r?lirlrr)?)?I?I
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354038871600000000029700
Discover More Card Account Summary
Closing Date: November 10, 2007 page 1 of 2
, Account number ending in 0830 Previous Balance $3,722.42
'Payment Due Date December 9, 2007 Payments And Credits 0.00
Minimum Payment Due $297.00 Purchases + 78.00
Credit Limit $3,500.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $1,800.00 Finance C aTees +
86.74
Cash Credit Available $0.00 _
New Balance _
$3,887 16
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
'Cashback Bonus® Opening Cashback Bonus Balance $ 12.41
New Cashback Bonus Earned + 0.00
Cashback Bonus Balance $ 12.41
Cashback B6nui® Srice Anniversary Date Available to Redeem - - - - - - $ _ _ _ 0.00- -
of April 10: $12.41
How Can We Help You?
P 1 . Visit Discover.com to pay your bill for no cost, view your
l
atest Account information, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1.800-DISCOVER (347-2683) for fast
easy self-service
Please have your Discover Card available. ,
options or to speak with a Customer Service Account Manager
For TDD assistance for hearing impaired) see reverse side
( 3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Trans. Post
Date Date
Other/Miscellaneous Nov 10 Nov 10 OVERLIMI T FEE $ 39.00
Nov 10 Nov 10 LATE FEE 39.00
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
* * * ATTENTION * * * We previously requested the past due amount on your account. We have no record of receiving
payment. The amount due should be paid at once.
VIa<. V CR
CARD
Br " ighte. j Account number ending in 0830
Have a question? Talk to us
There's no telling when you might have a question about your Discover" Carc
account. Which is why we're here 24 hours a day, 7 days a week. Perhaps
best of all, you'll be connected to one of our friendly, knowledgeable
Customer Service Representatives in less than a minute. Real answers from
real people. It's just one of the ways we put you first.
Call us of 1-800-DISCOVER (1-800-347-2683)
02007 Discover Bank, Member FDIC
Closing Date: November 10, 2007 page 2 of 2
Finance Charge Summary
Average
Daily Nominal
ANNUAL
ANNUAL
Periodic Transaction
Fe
Daily
Balances
Periodic
Rates
PERCENTAGE
RATES
PERCENTAGE
RATES
FINANCE e
FINANCE
CHARGES CHARGES
current billing period: 31 days
Purchases $3496.40
Cash Advances $267
83 0.07395% 26.99% F 26.99% $80.15 none
. 0.07942% 28.99% F 28.99% $6.59 $0
The rates that apply to your Account are either fixed (F) or the y may vary (V) as noted above.
Questions? Manage your account at Discover.com or
r,.,ll 1_ann_ni!crnvGD ti ann oA701,aot
UIZ)`.' V CK $4,058.85
CARD
10 SDSN6A01 0001827
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA 17266-0111
$406.00 I Enter Amount Enclosed Below
Payment Due Date $ 1- 7
January 9, 2008 Please make check payable to Discover Card.
You are overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
$558.85.
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
Discover.com/payments today.
illrrrrrrllllrrrlrlrrl
PO BOX 71084 Ill 11
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354040588500000000040600
Discover More Card Account Summary
Closing Date: December 10, 2007 page 1 of 1
Account number ending in 0830 Previous Balance $3,887.16
Payment Due Date January 9, 2008 Payments And Credits 0.00
Minimum Payment Due $406.00 Purchases + 78.00
Credit Limit $3,500.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $1,800.00 Finance Charges + 93
.6
9
Cash Credit Available $0.00 New Balance _
_
$4,058.85
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
'Cashback Bonus® Opening Cashback Bonus Balance $ 12.41
New Cashback Bonus Earned + 0.00
Redemptions This Period 12.41
Cashbdck BoriLmO Since Anniversary Date Cashback-Bonus-Balance $ --0-.00
of April 10: $12.41 Available to Redeem $ 0.00
How Can We Hel You?
p 1 • Visit Discover.com to pay your bill for no cost, view your
l
atest Account information, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1.800-DISCOVER (347-2683) For fast
easy self-service
Please have your Discover Card available. ,
options or to speak with a Customer Service Account Manager
For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 8,4130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Trans. Post
Date Date
Other/Miscellaneous Dec 10 Dec 10 OVERLIMI T FEE $ 39.00
Dec 10 Dec 10 LATE FEE 39.00
Information For You
* * * ATTENTION * * * Your account is seriously past due. Payment of the amount due and arrangements For future
payments should be made immediately.
Finance Charge Summary
Average
Daily Nominal
ANNUAL
ANNUAL
Periodic Transaction
Fee
Daily
Bal Periodic
R PERCENTAGE
RATES PERCENTAGE FINANCE FINANCE
ances ates RATES CHARGES CHARGES
current billing period: 30 days
Purchases $3657.88 0.07942% 28.99% F 28.99%
$87.15
none
Cash Advances $274.39 0.07942% 28.99% F 28.99% $6.54 $0
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above
VIJt.%'Y C:K 54,237.98 5523.00 I Enter Amount Enclosed Below
CARD
Payment Due Date
February 9, 2008 Please make check payable to Discover Card.
You are overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
10 SDSN6A010001828 $737.98.
CAHAN, DAN
PO Will your payment get to us on time? Pay
your bill online and your
a
ment can be
BOX 111
WALNUT BOTTOM PA 17266-0111 p
y
made to your account on the same day. Visit
Disc over. cam/payments today.
PO BOX 71084 Ill iIll I 1111111
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354042379800000000052300
Discover More Card Account Summary
Closing Date: January 10, 2008 page 1 of 1
,Account number ending in 0830 Previous Balance $4,058.85
Payment Due Date February 9, 2008 Payments And Credits 0.00
Minimum Payment Due $52100 Purchases + 78.00
Credit Limit $3,500.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $1,800.00 Finance Charges +
101.13
Cash Credit Available $0.00 _
New Balance _
= $4,237.98
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
!Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 0.00
Cashback Bonus Balance $ 0.00
Cashback Bonus® Since Anniversary Date -Available do Redeem- - $ - -0.00 -
of April 10: $12.41
How Can We Hel You?
I? 1. Visit Discover.com to pay your bill for no cost, view your
l
atest Account information, earn and redeem rewards and more
,It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for Fast
easy self-service
Please have your Discover Card available. ,
options or to speak with a Customer Service Account Manager
For TDD
(assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Trans. Post
Date Date
Other/Miscellaneous Jan 10 Jan 10 OVERLIMI T FEE $ 39.00
Jan 10 Jan 10 LATE FEE 39.00
Information For You
* * * ATTENTION * * * Your account is seriously past due. Payment of the amount due and arrangements for future
payments should be made immediately.
Finance Charge Summary
Average
Daily Nominal
ANNUAL
ANNUAL
Periodic Transaction
Fee
Daily
Balances Periodic
Rates PERCENTAGE
RATES PERCENTAGE
RATES FINANCE FINANCE
CHARGES CHARGES
current billing period: 31 days
Purchases $3826.46 0.07942% 28.99% F 28.99% $94
21 none
.Cash Advances $281.11 0.07942% 28.99% F 28.99% .
$6.92 $0
,The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
L) 130. V CK
CARD
1 0 SDSN6A01 0001829
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA
$4,421.57 1 $644.00 Enter Amount Enclosed Below
Payment Due Date $ 1 1
March 9, 2008 Please make check payable to Discover Card.
Minimumpa ment due includes a past due
amount of $523.00.
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
17266-0111 Discover.com/payments today.
PO BOX 71084 111111111111111111111111111
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354044215700000000064400
Discover More Card Account Summary
Closing Date: February 10, 2008 page 1 of 2
Account number ending in 0830
Payment Due Date March 9, 2008
Minimum Payment Due $644.00
Credit Limit $3,500.00
Credit Available $0.00
Cash Credit Limit $1,800.00
Cash Credit Available $0.00
Previous Balance $4,237.98
Payments And Credits 0.00
Purchases + 78.00
Cash Advances + 0.00
Balance Transfers + 0.00
Finance Charges + 105.59
New Balance = $4,421.57
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashbook Bonus Earned + 0.00
Cashback Bonus Balance $ 0.00
Cashback 136nusc9 Since Anniversary Date - - - - - - Available- to Redeem - - s- 0.00- - - -
of April 10: $12.41
How Can We Help You?
p 1. Visit Discover.com to pay your bill for no cost, view your
l
t
A
f
a
est
ccount in
ormation, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
Please have your Discover Card available. options or to speak with a Customer Service Account Manager
For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Trans. Post
Date Date
Other/Miscellaneous Feb 10 Feb 10 OVERLIMIT FEE $ 39.00
Feb 10 Feb 10 LATE FEE 39.00
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
* * * ATTENTION * * * Your account is seriously past due. Payment of the amount due and arrangements for future
payments should be made immediately.
vll?L?? v CK
CARD
L..1 Account number ending in 08JU
r _Bri
Have a question? Talk to us
There's no telling when you might have a question about your Discover" Carc
account. Which is why we're here 24 hours a day, 7 days a week. Perhaps
best of all, you'll be connected to one of our friendly, knowledgeable
Customer Service Representatives in less than a minute. Real answers from
real people. It's just one of the ways we put you first.
Call us at 1-800-DISCOVER (1-800-347-2683)
(52007 Discover Bank, Member FDIC
Closing Date: February 10, 2008 page 2 of 2
Finance Charge Summary
Average
Daily Nominal
ANNUAL
ANNUAL
Periodic Transaction
Fee
Daily
Balance Periodic
R
t PERCENTAGE
RATES PERCENTAGE FINANCE FINANCE
s a
es RATES CHARGES CHARGES
current billing period: 31 days
Purchases $4000.73 0.07942% 28.99% F 28.99% $98.50 none
Cash Advances $288.12 0.07942% 28.99% F 28.99% $7.09 $0
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
Questions? Manage your account at Discover.com or
--It 1_onn_nicrnvco 11 QOn )A70Aa?t
UQ) .VV Cot
CARD
10 SDSN6A010001830
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA
$4,602.56 1 $762.00 1 Enter Amount Enclosed Below
Payment Due Date $ 1
April 9, 2008 Please make check payable to Discover Card.
Minimum pa ment due includes a past due
amount of $644.00.
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
17266-0111 Discover.com/payments today.
PO BOX 71084 I?Irrrllrrrrrrllllrrrlrlrrl
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354046025600000000076200
Discover More Card Account Summary
Closing Date: March 10, 2008 page 1 of 2
, Account number ending in 0830
Payment Due Date April 9, 2008
Minimum Payment Due $762.00
Credit Limit $3,500.00
Credit Available $0.00
Cash Credit Limit $1,800.00
Cash Credit Available $0.00
Previous Balance $4,421.57
Payments And Credits 0.00
Purchases + 78.00
Cash Advances + 0.00
Balance Transfers + 0.00
Fina
n
ce Charges + 102.99
_
_
New Balance $4,602.56
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
'Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 0.00
Cashback Bonus Balance $ 0100
Cashback 66nusS Since Anniversary Date Available-to Redeem - - - - - - - - - - $- - - - - 0.00 - . -
of April 10: $12.41
How Can We Help YOU?
P 1. Visit Discover.com to pay your bill for no cost, view our
latest Account information, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
Please have your Discover Card available. options or to speak with a Customer Service Account Manager
For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Trans. Post
Date Date
Other/Miscellaneous Mar 10 Marl 0 OVERLIMIT FEE $ 39.00
Mar 10 Mar 10 LATE FEE 39.00
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
* * * ATTENTION * * * Your account is seriously past due. Payment of the amount due and arrangements for future
payments should be made immediately.
IVrZI%.1 V r-M,
CAR"
I Ak_
r' h
Have a question? Talk to us.
There's no telling when you might have a question about your Discover" Card
account. Which is why we're here 24 hours a day, 7 days a week. Perhaps
best of all, you'll be connected to one of our friendly, knowledgeable
Customer Service Representatives in less than a minute. Real answers from
real people. It's just one of the ways we put you first.
Call us at 1-800-DISCOVER (1-800-347-2683).
02007 Discover Bank, Member FDIC
Account number ending in UbJU
Closing Date: March 10, 2008 page 2 of 2
Finance Charge Summary
Average
Daily Nominal
ANNUAL
ANNUAL
Periodic Transaction
Fee
Daily
Balances Periodic
Rates PERCENTAGE
RATES PERCENTAGE
RATES FINANCE FINANCE
CHARGES CHARGES
current billing period: 29 days
Purchases $4176.03 0.07942% 28.99% F 28.99% $96.19 none
Cash Advances $295.06 0.07942% 28.99% F 28.99% $6.80 $0
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
Questions? Manage your account at Discover.corn or
--II i_onn_ntcrnvco ti onn o t? ??a?t
9)IJ`[. V tK
CARD
$4,795.24 $892.00 Enter Amount Enclosed Below
10 SDSNBA010001831
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA 17266-0111
Payment Due Date $
May 9, 2008 Please make check payable to Discover Card.
You are overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
$1,295.24.
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
Discover.com/payments today.
PO BOX 71084
CHARLOTTE NC 28272-1084
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354047952400000000089200
Discover More Card Account Summary
Closing Date: April 10, 2008 page 1 of 1
Account number ending in 0830 Previous Balance $4,602.56
Payment Due Date May 9, 2008 Payments And Credits 0.00
Minimum Payment Due $892.00 Purchases + 78.00
Credit Limit $3,500.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $1,800.00 Finance Charges + 114.68
Cash Credit Available $0.00 New Balance = $4,795.24
You may be able to avoid Periodic Finance Charges, see the
reverse side for details.
Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 0.00
Cashback Bonus Balance $ 0100
_ 0,00 -
Cashback BbhOA D AriniJet§ary Available to Redeem - - - - - - - $_ ... _0,00
Date: April 10
How Can We Help YOU? 1 • Visit Discover.com to pay your bill for no cost, view your
P latest Account information, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
options or to speak with a Customer Service Account Manager
Please have your Discover Card available. 3. Write us at Discover Card, PO Box 30943,
For TDD (assistance for hearing impaired) see reverse side Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Trans. Post
Date Date
Other/Miscellaneous Apr 10 Apr 10 OVERLIMIT FEE $ 39.00
Apr 10 Apr 10 LATE FEE 39.00
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement For
details.
Finance Charge Summary
Nominal
Average Daily ANNUAL ANNUAL
Daily Periodic PERCENTAGE PERCENTAGE
Balances Rates RATES RATES
current billing period: 31 days
Purchases $4355.64 0.07942% 28.99% F 28.99%
Cash Advances $302.17 0.07942% 28.99% F 28.99%
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
Transaction
Periodic Fee
FINANCE FINANCE
CHARGES CHARGES
$107.24 none
$7.44 $0
UIJUr V tK $4,795.24
CARD
08 SDSN6A01 0001833
CAHAN, DAN
PO BOX 111
WALNUT BOTTOM PA 17266-0111
$4,795.24 Enter Amount Enclosed Below
Payment Due Date $ ?-
DUE IMMEDIATELY
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
Discover.com/payments today.
PO BOX 6103 11111 [111
CAROL STREAM IL 60197-6103
Address, e-mail or telephone change? Print change in space
above, or go to Discover.com. Print your e-mail address to
receive important Account information and special offers.
000001986458363274354047952400000000479524
Discover More Card Account Summary
Closing Date: May 8, 2008 page 1 of 1
Account number ending in 0830 Previous Balance $4,795.24
Payment Due Date June 7, 2008 Payments And Credits 0.00
Minimum Payment Due $4,795.24 Purchases + 0.00
Credit Limit $3,500.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $0.00 Finance Chaaes _ + 0.00
Cash Credit Available $0.00 New Balance $4,795.24
Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 0.00
Cashback Bonus Balance $ 0.00
Available-to. Redeem _ 0.00
_Coshbaek B6riU5eAhfiiVeFSaty
Date: April 8
HOW Can We Hey YOU? 1. Visit Discover.com to pay your bill for no cost, view your
p latest Account information, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1.800-DISCOVER (347-2683) for fast, easy self-service
options or to speak with a Customer Service Account Manager
Please have your Discover Card available. 3. Write us at Discover Card, PO Box 30943,
For TDD (assistance for hearing impaired) see reverse side Salt Lake City, UT 8,4130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
Finance Charge Summary
Nominal Transaction
Average Daily ANNUAL ANNUAL Periodic Fee
Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE
Balances Rates RATES RATES CHARGES CHARGES
current billing period: 8 days
Purchases $0 0.07942% 28.99% F 28.99% $0 none
Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0
previous billing period: 20 days
Purchases $0 0.07942% 28.99% F 28.99% $0 none
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above
CERTIFICATE OF SERVICE
A true and correct copy of Plaintiff's First Request for Production of Documents and
Request for Admissions has been served by U.S. Mail, on the ?4 day of 6U-0k ,
2009, upon the following:
Dan Cahan
304 N Fayette St. #102
Walnut Bottom Pa 17226
CERTIFICATE OF SERVICE
A true and correct copy of the within Plaintiff's Motion for Summary Judgment and Brief in
Support has been served by U.S. Mail, Postage Pre-Paid, on day of , 2009 upon the
following:
Dan Cahan
304 N. Fayette St., #102
Walnut Bottom, Pa 17266
By:
1-777
BenjamiK Bibler,Esquire
PA ID#/93 8
Weltma , einberg & Reis CO L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA. 15219
OF 7HI P,",' 2009 AUG 18 Phi I. 0+ 8
I -Y
DISCOVER BANK, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
DAN CAHAN,
DEFENDANT 08-5088 CIVIL TERM
IN RE: MOTION FOR SUMMARY JUDGMENT
BEFORE BAYLEY, J. AND EBERT, J.
ORDER OF COURT
AND NOW, this 1b day of October, 2009, the motion of plaintiff,
Discover Bank, for summary judgment against defendant, Dan Cahan, IS GRANTED.
Judgment is entered in the amount of $4,795.24.
-/"Benjamin R. Bibler, Esquire
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
Dan Cahan
304 N. Fayette Street, #102
Walnut Bottom, PA 17266
:sal
yes m,alrtcL
COP
FILED-t.1,
OF TNr P-` , .; ` R,n.IOTAPY
2009 OCT i G Ah 9: 55
u NH
0
w
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
Case No.: 08-5088 CIVIL TERM
TYPE OF PLEADING
vs.
DAN CAHAN
Defendants.
PRAECIPE FOR JUDGMENT
PER ORDER OF COURT
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Benjamin R Bibler, Esquire
PA I.D. #93598
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 6861146
w
jr
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
DAN CAHAN
Defendant.
TO THE PROTHONOTARY:
Case No.: 08-5088 CIVIL TERM
PRAECIPE FOR JUDGMENT
Pursuant to Pa.R.C.P. 237, I certify that a copy of this Praecipe has been mailed to each other
party who has appeared in the action or to his/her Attorney of Record.
In light of the Court Order granting Judgment in favor of Plaintiff on October 16 2009, kindly
enter Judgment against the Defendants, Dan Cahan, in the amount of $4,795.24 computed as follows:
Amount Awarded per Order: $4,795.24
Interest from Date of Judgment
at the legal rate of 6% per annum:
TOTAL: $4,795.24
Attached is a copy of the Court Order in favor of Plaintiff for Judgment.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
By:
PA I.D.98
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
Plaintiff's address is: Weltman, Weinberg & Reis, 1400 Koppers Building, 436 7t` Avenue, Pittsburgh, PA 15219
And Defendant's address is: 304 N Fayette St #102 Walnut Bottom PA 17266
W WR No. 6861146
w
DISCOVER BANK, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
DAN CAHAN,
DEFENDANT 08-5088 CIVIL TERM
IN RE: MOTION FOR SUMMARY JUDGMENT
BEFORE BAYLEY J. AND EBERT J.
ORDER OF COURT
AND NOW, this 1b day of October, 2009, the motion of plaintiff,
Discover Bank, for summary judgment against defendant, Dan Cahan, IS GRANTED.
Judgment is entered in the amount of $4,795.24.
Benjamin R. Bibler, Esquire
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
Dan Cahan
304 N. Fayette Street, #102
Walnut Bottom, PA 17266
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff Case No.: 08-5088 CIVIL TERM
vs.
DAN CAHAN
Defendant.
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendants
( ) Garnishee
You are hereby notified that t e following Order or Judgment was
entered against you on
(xx) Assumpsit Judgment in the amount
of $4,795.24, plus interest at 6% per annum, plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle
operator's license and/or registration will be suspended by
the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
(xx) Court Order
( ) Non-Pros
( ) Confession
( ) Default
( ) Verdict
( } Arbitration Award
( ) By Consent
Dan Cahan
304 N Fayette St #102
Walnut Bottom Pa 17266
Prothonotary
W WR No. 6861146