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Home My WebLink About09-8350 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 0c?_ 3 sC) VS. COMPLAINT IN CIVIL ACTION JENNIFER A RUIZQUINONES Defendant 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 07887076 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No JENNIFER A RUIZQUINONES 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, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 2. Defendant is adult individual(s) residing at the address listed below: JENNIFER A RUIZQUINONES 82 LINDA DR MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1249 . 4. Defendant made use of said credit card and has a current balance due of $1366.09 , as of September 10, 2009 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 26.9909. per annum on the unpaid balance from September 10, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 111" and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 . 9. 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 , JENNIFER A RUIZQUINONES individually , in the amount of $1366.09 with interest at the rate of 26.990% per annum from September 10, 2009 plus attorneys' fees of $125.00 , and costs. James C. IfArmbrodt,42524 WELTMAN, INBERG & REIS CO., L.P.A. 436 Seve Avenue, Suite 1400 Pittsbur h PA 15219 (412) 43 955 FAX: 41 - 38-7130 0788707 C A Pit KMJ This law firm is a debt collector attemptintf to collect this debt for our client and any information obtained wilil be used for that purpose. ** DISCOVER CORD New Balance Minimum Payment Due $1,366.09 $1,366.09 Payment Due Date October 10, 2009 15 SDSN6A01 0004170 1 JENNIFER RUIZOUINONES 82 LINDA DR MECHANICSBURG PA 17050-1549 Account Number ending in 1249 Enter Amount Enclosed Below Please make check payable to Discover Card. Minimum yment due includes a post due amount of $281.00. Will your payment get to us on time? Pay your bill online and your payment can be mods to your account on the some day. Visit Discover.com/payments today. PO BOX 6103 llll$gill loll Nile lrlrrlrrll CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Print change in space (?llnllr,nulli?lrnlunll?lnnrl?llnurlln?luurl?u?ul? above, or go to Dixover.com. Print your e-mail address to receive important Account information and special offers. 000001986458738218458013660900000000136609 Discover Motiva Card Account Summary Closing Date: September 15, 2009 page 1 of 1 Account number ending in 1249 Previous Balance $1,366.09 Payment Due Date October 10, 2009 Payments And Credits 0.00 Minimum Payment Due $1,366.09 Purchases + 0.00 Credit Limit $750.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $0.00 Finance s + 000 Cash Credit Available $0.00 -- New Balance ---- - $1,366.09 Cashback Bonuse Opening Cashbock Bonus Balance $ 0.00 New Coshback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary Date: September 15 HOW Can We Help You? I Visit Discover cores to pay year hill! for no cost, view ur p latest Account information, earn and redeem rewarcr31 more It's your choice - 3 ways to help 2. Call 1-8004YSCOVER (347-2683) for fast, easy self-service Please have your Discover Card available. options or to speak with a Customer Service Account Manager 3 . Write us at y, UT 8 Card, PO Box 30943, For TDD (assistance for hearing impaired) no reverse side Salt Lake City, UT 8 4130 Transactions $0 Fraud Liability Guarantee U. your Discover Card with confidence. Information For You Your Account is overlimit. While we are permitted under the Cardmember Agreement to charge you an Owrlimit Fee, we have chosen not to do so at this time. We reserve the right to do 30 if, as of the close of a billing period, your outstanding Account balance exceeds your Account credit limit. See the Overlimit Fee section of the Cardmember Agreement for details. wrMr: ? Finance Charge Summary ' ' Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee s Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Bolcince Rates _ RATES RATES CHARGES awas K current billing period: 15 days Purchases $0 0.07395% 26.99% F 26.99% SO $0 Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) 03 noted above. i Ntarrt laiernrtlan. 11 there is more than one page to this billing statement see the back of each page for additional important information. ywr CWdrmn bw Apaement. Your Cardmember Agreement contains all the terms of your Account y?wU"sphlown yeuW6..IIRReport immediately!Ran Carll 11e?0-84o7-p2?uO3.. 0D1i you 9 you Kit dal le WO mU Aihetamr?ufrro rtm aWr n 60 your at q? ?? I + the on 9 ; bill on whlihl the errorrkwClty..nUT?eaa 30 0421V as cane telephone Ib num iur _d ISO d- r 0 ror"'anof the d eexpi it rights. why you believe there is an error. H you need more Information. describe the Hem you are unsure ib not have to ppaayv an? amount In question while we are !nvesbrUen a, but you are still oblicled to pav N of your bill that are not in iUan. While we InHaaIr?ate your question, we cannot report you a3 dnquerri or take any ad0on to cblldct NE amount you question. ??,}? ?,hdnees: If nave a with thvep quaa?iyty of orpaxylvfces Natrtvlonup purchased with aeodooHdsprQ and hr IN on" Uppbwthe am VA is merc pautrefehase oriceth 1 than u and the purchase vYasNmade all your h e state oorr w?itltih 100 or miles oies. erchant a H we malted you the advertisement for the goons or services, all purchases arc covered merits dr Ne a moSlnt a I ptiwa i)1 prrchasert)f ?arrb Send and vwr oavment and th aortion of this s to tin the mvelooe ordvldad. po not send rash. sendin r check as xipad aboveaUanMeu?so t use tnalionr cn?k make an electrauc'Tund Vansiw lrom your nt at N? ?Inanei 1 ction. If an elatrak fMUnC trelansfeer ifun fund transfer, the sttutio*1In? Ne amount or Vro db sanle seeiniawrmatih rk?Vansa ym !drawn rem your vaocvucroupnatVas soonaas Nedas?aamvaepday we receive your ent anrd4y?oru will not receive your check back from your finpaanvcimal heUaloroeassln0 d«n a Ytmke?itd at envMabaDe t? h??a? e ?!?q ?06 97-610 eaa ee ene? ?u On ?dav. H you he Iv1e lym?le ?aGll yesASOndayn to ?o?N„b,.rf?s r m ru??.r nank? hmcd 6 i 03. l'aid.? fdr every ?°U Idpe name, or Late its in amount we •nu mn amcu t may be less Nan orother pdoeffanullts on your a roPO Bex 15316 Imingttoonh orn the Transaction Date for the bin uy uio r. ?. wv ...w ..•, ?.. __.._... _..... ___. _ as ist appears g on the current bi Ing statement call Nis a °grace pen ere is no grace es. in l?u Im?roe you a( minimum FINANCE CCHARBEpof $.50 for any billing vppeeriod in which periodic Finance Charges Of aa50rs bnurNe Statarnntentswhennthe?e t fee isldUeOb Thlelwnualhice ifinnoitnrt fa au less w6 hoUi).95 that?vountwish?to close you Account >: Or the mailing or A•P?•^r; dale or the sratement nn wmCh the fee is billed. ou will receive Nis reiudd even It you use your Card inat Peifaa. k F omes We sortyour transa?uons Into rams of rchases, cash advances and balance transfers and then further ilort the tfon withi Cn NWrlo- teb1 theetrs Annual pertccentar plate.' For eQam?le rchaaseess sub ec1 to a ?motio?naall rate paend pu sutb?ect to a ?,Meci?nn._ fnirF?s ter?each des eot?the biilioepen?odp/or wNhntranacction o lCategorytWe useetheefoilwAngn?gUatdlo to rchasesputte dodic? Dally Balance) times (days in billing period) times (Daily Periodic Rate) refer to the finance charge summary on billfn9 statement for Ne a amounts.) Then we add ue the Periodic Finance Charges hfor e each E7 r Finance Cnarxf for your Account The Average Dally Balance u? shown as zero if, because of the grace ich we im a Periodic Finance poi nas in a billing pears for a transaction cateoorry b?ance for. _.?.__ .._ .}he ?.. nor reau? Oalana tF3nsactians wIN 0 TransactloX Date of that day as shown on your the stn lard purchase Vt I a`f trons/er aare abbeend w hated soot uwaii • -- tansacU on ee inanceCcur b term the rice T n ter inated under Me .it Rate section, we !cave the u card balance of the balance Va f inance Charges in the app! cable balance transfer transaction category until the special rate w ;. For TDD (TdecoM VMcabm Devtee fw tare Des) aaabtarrce, pease Call 1-900.947-7449. 0 w 0 S S the Fee which has VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is James Ball (Name) Team Lead _ of DFS Services LLC , plaintiff herein, that (Title) (Company) he 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 knowledge, information and belief. WWR# 7887076 Jennifer A. Ruizquinones '6011002632961249 C? $--I g-, S-01d- C A 1,134 376 a?r ?