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Home My WebLink About12-6676IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL DIVISION c-> C .•.~ '~ ~ ~' z ~ c°-~ rn _-~r Z ~ r --~ -vs t ~Z, ~ ~~ T" ~ `-+O D ~ ~'"' ~ c~.~- ~~ ~c'7 _.,,~ r. ' ' PENNSYLVAN'iSA ~ ~ Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff No: ~~- (0 (0 ` ~o ~~ v ~ ~G P/r--, vs. GEORGE KATSIFIS Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T_ Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A_ 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 09720995 C A Pit SJS C ~ l0 751 ~7/ ~ ~ ~.~~ x/78 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff vs. Civil Action No GEORGE KATSIFIS 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 banking institution organized under the laws of the State of Delaware and maintains a business address of 12 Reads Way, New Castle, DE 19720. 2. DB Servicing Corporation is the servicing affiliate for Discover Bank, f/k/a Greenwood Trust Company, an FDIC-insured Delaware State bank. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including, business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the account to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. 3. At all times pertinent hereto, DB Servicing Corporation is the servicing affiliate for Discover Bank, in reference to Defendant account, which is the subject of this litigation. 4. Defendant is adult individual(s) residing at 1777 SHEEPFORD RD MECHANICSBURG, PA 17055 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX6873 6. Defendant made use of said credit card and has a current balance due of $8031.73 A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" 7. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 8. Although repeately requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due the Plaintiff. WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant, GEORGE KATSIFIS ,INDIVIDUALLY in the amount of $8031.73 with interest at the statutory rate of 6.00 °s per annum from date of judgment and costs. ~~ - Wi iam T. o cza ,47437 WELTMAN, WEINBER & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR# 09720995 C A Pit SJS This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. ~'SC ~VER S 03173Ce 22 SDSN6AOt 0003761 GEORGE KATSIFIS 1777 SHEEPFORD RD MEGHANICSBURG PA 17055-484 Addreu, «maR a telephone chonge9 Go b www.lliseovercem or p-iM clangs in specs PO BOX 6103 Illsss{Isrrrrlslsslslr{Isrl CAROL STREAM IL 60197-6103 H~gIT Irllrrllrrrrrrlllrlrrlrrrlrflrrrrrllllrrrrrflrllrrrrrllrrlrrll 0000019864588924167730810317300000000803173 >tsanin8 Data: Juno 1, 2014 - Qaafng D'ISCOVSr More Card Account Sul Account number ending in 6873 Minimum Payment Due 1 Account Number ending in 6873 58,031.73 J Enter Amount Enckrsed Bsbw Payment Dus Oafs l Ju y 17, 2012 Wease make check payable ro Discover Card. MinimumppooyymmeM dw inckxles a p~ due amount of-i1,374.00. Phone and inNrnef enh must bs made by S:OOpm ET for some ~ t Ta drA~P t DfSCOV' t i fi b i o o rece ve a nk our free mobNe app and pey your bill In seconds from anywhere) .tuna «, Previous Babncs 58 031.73 Payments And Credits 0.00 Purchases + 0.00 Balance Transfers + 0.00 Cosh Advances + 0.00 Foos Charged + 0.00 Interest Cho sd + 0.00 New Ba once 8 D31.73 Sae Interest Charge Cakubfion section fnlbwirg hansactions far debiled APR informdion Credit Line 57,~t00.0o Credit Lino Avaibble i 50.00 Cash Advance Credit line 50.00 Cash Advance Credit line Awiloble 50.00 wsnwvcR ovnvs Anniversor~ Mordh I May Opening Coshback Bonus Baance S 0.00 New Coshb«k Bonus This Period + 0.00 tos6b«k dares flelarrce 5 0.00 1'o Man mac, b8 M a www.0iacowr.anm 3 Easy Ways to Contact Us ~ 1 Accsu your «caxrf securely d www.Drscowr an 2. Cab 1-804DISCOVER (1-800347.2683) Please haw your Discover. card avaib 3. Writs b us d Discover PO Box 30943, Sob take City, UT 841$0 (Nd o payment ad u) For paymsrds, send b address on rem' a Discover, PO x A103, Card Stream, K 60197 03 For TDD (Telecommunications Device for dre Deof) auisbnce, please call 1-800.347-7449. ...~ ~ rays ', Payment Information New Babnu =8,031.73 Minimum Payment Due• 58,031.73 Payment Dw Date July 17, 2012 ~ •Includss past due amount of 51,374.00 lass Payrnenf Wemig: IF vw do rat receive your minimum i payment by firs dots lisHd above, you may haw fo pay o Ids fee of up ro 635.00 and your porches. and bobnce transfer APRs for raw hwssactions maybe increased up ro the Penally APR of 16.24'.5 variable. Minimum Paysrserrf Warning: If you make only the minimum paymerrl each period, you will pay more in irrNrest and B wiN take you kxrg.r ro pay off your babnce. For.xample: fits fat~i :; d~iaktn,ftr •, >: ,:: . ~ ~ of Only the minimum payment i 3 years 58,032 If you would like information about credit counseling services, caN 1-800.347.1121 Manage Your Aaount Online at www.Discov~r.com • Accsu Free online bah like Poydown Pksnrwr b credo o plop ro down your babnce, securely «eeu atahmenfa, Pay big= online and easily hack atl hansocfiorrs • Mdse your money worth mono-find easy ways b cam and redeem cash rewards • NEWT Accus your account securely through your mobile phone Transactions Trans. Post 9720995 i>a+. llaf. Fees T AL FEES Fes! TENS PERIOD S 0.00 h/erest Charged T Al IMFlEST FOa TItlS PERIOD S 0.00 2012 Totals Yearto-Date T Al FEES CHARGED IN 2012 5 173.00 T AL INTEREST CHARGED IN 2012 362.33 NOTICE; SEE REVERSE SIDE FOR IMPORTANT DISC "AVER nPey,ro ~ ~ cEORCE KATSIFIS ~~Y>~ _ Account number ending in 6873 I page 2 of 2 Interest Charge Calculation Your Annual Percsnbgs Rate (APR) is the annul interest rob on your account. Currsrsf bilisg pried: 22 days TYPE OF BAIIJrCE ~ f~ERCENTAGE Y~ ~ TO NVTHtEST CHARGE f''achaws 11.24 V s0 ZO Cash Advcsrces 23.99% V SO ZO V =Variable Rate Additional ioperlaM bFsrsrralisn See year Cardnsembsr AgrewrrwM. Your C ber Agreement contains all the forms of your Aaount. lost er slelse carols. Report imrnediablyl Coit 1 -2683. IF you think Mrere is an error on your sbbmerd, v+~ In your letter, give us the FoNowmg Mfamafion: Account information: Your name and Donor amount The doNor omouN of the Dew, riafion of Probbm: If you think tlnrs ~' i sam e. You must contact us within e30 days after the You must notiFy us of any potential errors in ~ potential errors and you may haw b payiFw While we imresligate whether a not Intro ha We eamot try b eoNed iFre amount in qa The in maayy remain on ws determine t~made o misfdrs, y~ro b that amount. • While you do not haw b the amount Ws can apply arty unpaid amarnf ogoins IF you are dissatisfied wNfr Ito sass in good Foilh b eared the with tl dw an the purchase. To use This right, aN of the Folbwing must I 1 The purchase must how been mode to the purchase price must haw been mat based on an adverfisemsnt we maild I 2. You must taw used your credB card Fo chock Ihd accesses your credit cord ac 3. You must not yet taw fully paid Far the If aN of Nre criteria above are mN and) Dixover, PO Box 30945, Sak lake CN While we inwsfigate, dre same rrrlss aF inwstigdion, we wiN teN you our lector may report you ors dslirrquer>f. -ayrnenb. You maypay aN a port of your Aaou Payment Due by the Payment Dw Date. Send onF profiled. Do rat send rnsh. BY sending your chi fo make an electronic fund transfer Gam your acco payment ~ o ehedr hansaction. If paym rs prc the efroek. WMn vw use inFormation 6om~your el account as soon as Brs same day we reuiw your inalihAion. e to us at: Dixover, PO Box 30421, Sok lake City, UT 84130-0421 ant number. spotted error. an error on your biN, dsxribe what you below is wrong and why you bellow nrror appeared on your sto~srnsrd. ~. You may cosh us, but iF you do VNe are not required b invssNgate arty osmownt in quealion. been an era, the folbwing an trw: ~tion, a report you as dslinqusnt on that amount. r statement, and vw may eontlnue b drarge you Infenaf on that amount. But, if will not haw b pay IFre amount in quedion a any interest a other fee: rekrted n question, you an responsible for the remainder of your bakxrce. your credit lima. ea Ihol you haw purchased with your eredH cad, and you haw tried merchant, you may haw the right rat b pay Ihs remaining amount hue: ur hams state a within 100 mike of your eummt mailing address, and pan 550. (Nob: Neither of these are necessary iF yaw purclass was iron a if we own the comparry that sold yov the goods a ssrvi~.) w rchase. Purchases mods with cash advances from on ATM a with a unf do not qualify. irehose. i are stiN dissafi:(ied with Ihs purchaas, contact us in writir p ot: UT 841300945 y b th. disputed amowd as dixussed above. Aker we finish our . Ai that point, if ws Ihink you owe an amount and you do red pay we baksncs d any time. However, you must pay at Isosf dre Minimum lour payment and drs fop portion of this sblernerrF in Ilrs envelope ~ as dexribed above, you aulFrains w b ass information on yaw chock k d the financial insltlution indicated on your chock a b procsu the ased os an ekxhonie (and booster dre transerr wiN bs For the amount of :k b make an slsehonie Fund trar-s~er, Funds maybe withdrawn From your symsnt, and you wiN not receive your chock back Fran your financial The proceu'ng of your payment may bs dsksysd if send veep, correspondence a other items with your payment, if you sand N-s poynrent fo arry other adrirat a tf yar u err snwtops other than the one provided. Poymerds rscervsd in proper form at our processins Facility SPM k~ed time any ~y wiN be exedited b your Account as of that day Payments received of our processing keili aRer SPM kxd a v~nll f» credited b yax Account os of tfn next day IF yar how misplaced ~ errwbps, sand your payment b Di over, PO Box 6103 Carol Sheam, IL 60197-0103. FMsase dkrv 7.10 days For ds ivory. IF yaw payment ra unpa~d, we reserve the rig~f b rewbmif if as an eledranic debit. You can pay monthly Minimum Paym over TM or can setup twtorr 1-800.347. 683. Automatic payments w dab (e.g. fhs 15th day of tfa month) that your eMchonic aigrwlwe, you will be tsgreei authorize, in the amount selected by you, fn your bank account, as applicable, fo tome payment by phtxa ~ 1.800-347.2683 a h must ncetw notice d least Ihree business d ws wiN tell you on each montfdyy biting state that sufficient funds are availabb in your ba You can sat automatic payments For• (i) state Payment Ogre plus a fixed tdoYar amount, or the Minimum tsyment Dw m listed on yen increased ro cover the Minimum Payment D excess wiq be ied in xoordtsnce with y Bulona on your billing sldemeM, that pays ppaayment amount maybe less than the tame Cbsing Dab. If you enroN by phone in our automatic pwy for your records. Amount: ^ Full Pay ^ Min Pay Bank Routing Cndi We may report informal ofhw d~ your Account may be reA yaw Account b credB reporting agencies us a the ioNovring odrhesa: Dlxovw, PO home tekspllorn number and Aeeount rlum PoYig iY1M~sf: We begin to impose inbr dally ksnce. We continue ro impose ill inbrest on Purchases as dexribsd below. Advances. lF you paidtM Now BalarKe on your pre will not impose interest charges on raw P cumnt billing sMbment. Nsw Purchaass Ir you a0 rlar Pay your I~ew va~anc~ m non you may riot gat a grace period on raw Pu Haw tIW Cdcrrlate YrMreet Charges Drsiy each billing period by first figuring Ifte •doi standard P-wchases, standard Cash Advent How Mle Figure fire Dar'lyr lalarra far Gods We start with the inning btsbnc your boksnee on the Test day of y« We add any inbred charges accru add any new transactions or foss a which tM fransadion or fee posbd We subtract any new credits and p We make other adjustments (induct Fitwv IMe Figlwe Your Taal MMea Chape We muNiply the dally boltsnee for s tM biglrlg pert ~cl g~~s foal we divliddss ih• • We add up all file daily interest ch How W~ include fees We odd Balance Tronsfw Fses ro the t~pli Fees b 1FIe apppplicable Cash Advance 7lran Tranaoction Category. doi{aae Subject a irlerest Rae. Yow stab hansaction category. The Baksnce Subject period. Credit 6tslerrcee. If yaw Account has a cn A credit baksnce is mtxay that is owed ro open. We wip send you a refund of arty n required by applicobN k~w. For TDD (fnnilQQecQQo~~nrnunietrtierss Device for Ik Dist~TM1tljt'Y56nitor fled/or record telep purposes. The Dixovwmcord is issued by Dixovw I w, or a greater amount that does not exceed your curcerd Account balance, wymenfs 1Mough a customer service reprsserltative by calving dsducbd on the Payment Due Dote unless you regwst a reeumng poymsN s before yaw Ptryment Dw Dab. IF your xheduk+d payment dab togs on o proceaasd the business day prior to the weekend or barJc hdlday. In order w1A reed this sfalsrrlent and your bank account inFomwtion. You will be eid seewiy number of the primary btxrower. By pprrooviding those numbers as o this aulhorizaFion ro allow us and yaw bank ro deduct each paym.nt you your bank tsccolrnt. You also aulhonze us ro inifiab debR or endR enlria to error in the proeesairtg of such payment. You can cancel a xheduled ail d Diseovw, PO Box 30421 Sak Lake City, UT 84130.0421; however we in advance of the stdaduled payment. If yaw ptsymenri may vary in amount, >f vvllen your payment wiB be made and how much it wdl be. You must ensue xcourA, and all transactions must comply with U.S. law. nt New Balance, (ii) statement Minimum Payment Dw, (iii) stafwnsnt Minimum a (ilasd dollar amolud. If your sdheduled fired ptsymeM Is not en h ro cover bigi statement, your xhetduled payment for That month wil~ If the scheduled payment Is Than 1Fa Minimum Payment Dus, any Cordmembw Agreement. IFyour acMdlled payment is greater than TM New t wiN be eased on for die amount of yaw Nsw Balance. Your auTOmr>tic ndicabd on the periodic alatement based on aedih or payments oker the d service, please fitl•in the Following blanks bebw and retain the ouThorizotion ^ Min Pay + S ^ Fixed Pays Bank Account *: . Fregwncy: IlsolA yaw Account ro exedit bureaus. Lab payments, missed payments, or d in your credN ~reepp~orrtt. We normally report tFle stdus and payment history of month. If beliwe That our report Is tntstxlrrab a incompktRe please writ 15316, Ilmington, DE 198545316. Phase indicab your name, address, on o transaction Fee or inbreaf charge from the day ws odd it b the a until you pay ttie total amount yew owe us. You can avoid poyin8 you cannot avoid paying inbnst on Balance Trana(ers or Cash ~iment by the payment Dw Date shown on Neat biNirlg srohmeM, we anyy Portion of a new Purchase, paid by the Payment Due Dab on your a t}lat first appear on the curcsnt billing stdement. depending on the balance ro which ws apply your payment, d (ncludng t:utnent treneectien~: We cakuksb intenat charges each Transaction Category. Transaction Cateeggoories include r promotional balances, such as Balance TransMn. nsarcliers Cobgory sr each da~r. The beginning balance for the First day of the billing period is reviouut bll leg period on tFa previous day's daily balance and any new transactions and Fees. We f the ktbr of da Transaction Dab or the fief day of the billing period in yaw Account. those adjushnents required in the "Paying Interest" section). ~ Tronttaefion Category by th doily psnodic rob. We do this for each day in west charges far each Transaction category. To gsf a daily periodic rote, 'ransaefion Category by 365. ss. The wm is the total interest charge for the billing period. rte Balance Transfw Transaction - Na We odd Cash Advance lion Cabgory. We add all other fees ro standard Purchase nit shows a Balance Subject ro Intend Rab. M shows this for each Interest Rab is the average of the daily balances dwing the billing babrce, the amount is shown on the front of r billing statement. ~. You may make eha-gss against this am if your Account is lining balance of 61.00 or more o(hr 6 months, or as dherwise lea9 eesietaru, plwse eoN 1-800-347.7449. a calls between ytw and Dixovw representatives for tlualiy assurance Member FDIC RZNfE001 Questions? vl:It MrwN-.D• .oaln or DISCOVER tail 1 800-DISCOVER (1-800-3 -2683), VERIFICATION ~.~~ _ C a e ~~ o ~ A Le al Placement Account Mana er (Name) (Title) of DB Servicing Corporation, servicing affiliate of Discover Bank. (Company) does hereby verify, under penalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities states, that he/she is a duly authorized representative of plaintiff herein and authorized to make this verification, and that the facts sets forth in the foregoing Complaint are true and accurate to the best of his/her knowledge and information and that he/she is personally familiar with the account and the relationship between Discover Bank and DB Servicing Corporation. That Discover Bank, f/k/a Greenwood Trust Company, is aFDIC-insured Delaware State bank, and its servicing affiliate DB Servicing Corporation, extends credit through issuance of the Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. Date /~--Z~ " Z~IZ. GEORGE KATSIFIS XXXXXXXXXXXX6873 (Signature) DB Servicing Corporation serving affiliate for Discover Bank PO Box 3025 New Albany, OH 43054 WWR# 09720995 C A Pit SJS Poperless stateme mean less clutter, more convenience Easily access up to 24 months wnloadoble, password protected statements. • See your statement as soon it's available rather than waif For it to arrive in your mailbox. • Get helpful payment remin through e-mail or text massages on your mobile phone. • Print a paper copy of your temenf anytime. • Sign up today at Discovers /paprtless vzoio o~~. eon, M.•,~.r rac PAPER.0310 o_ v rn V 9720995 Questions? visit vvvvw cam or call 1.800-DISCOVER (1.800-3 -2683. ~SC~YER SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~,Utn et ~'utr~brr~h6 ~, ~ c~F~~c~ _~~ =H~ »~~~t~~ ZU12 Nt~V -9 QM S~ 35 CUMBERLAND GDUNTY PENNSYLVaNlA Discover Bank Case Number vs. 2012-6676 George Katsifis SHERIFF'S RETURN OF SERVICE 11/02/2012 04:55 PM -Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: George Katsifis at 1777 Sheepford Road, Lower Allen Township, Mechanicsburg, PA 17055. //~+ ~- J ON KINSLER, DEPUTY SHERIFF COST: $38.00 November 07, 2012 SO ANSWERS, «w RON R ANDERSON, SHERIFF {c! CountySuite Shsrift, Tslsosoft, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff " Jod y S Smith fi� i HE PR0 NG1i'ui Chief Deputy x Richard W Stewart Solicitor OFFICE OF TliE SHERIFP CUMBERLAND COUNTY PENNSYLVANIA Discover Bank vs. Case Number George Katsifis 2012-6676 SHERIFF'S RETURN OF SERVICE 02/15/2013 09:17 AM-William Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to James Ghafoori, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to him. The writ of execution and notice to defendant was mailed on February 20, 2013 to George Katsifis at 1777 Sheepford Road, Mechanicsburg, PA 17055. 09/04/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.93 SO ANSWERS, September 04, 2013 RON R ANDERSON, SHERIFF (c)CouhtySui!e Sheriff.Teleoso8, i