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Home My WebLink About12-7539ip1LC~-i.J~I fL+.4, 4 ~. ~'~f2~~~ ~~ Ah~~1~.~i ~etJ~~~~1\L~iiQ trVU~i i ~ ~'~:~{~SYLL`AN1A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servi.cing Corporation C q ~(v~l Plaintiff No: ~ ~' ~ J~ I vs. MANJUNATH K METI COMPLAINT IN CIVIL ACTION Defendant 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 30068690 C A Pit SJS C,~~ ~o~va~i ~~ as~r3~y 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 MANJUNATH K METI 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 failing 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 x-ights 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 Servici.ng Corporation performs a variety of services for Discover Bank including, business management services in support of Discover Bank business lines, ircluding, among other things, credit cards, deposits, personal loans acid student loans, customer service, co:Llections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts include: 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 11 RICHLAND LN APT 112 CAMP HILL, PA 17011 5. Defendant= applied for a:nd received a credit card bearing the account number XXXXXXXXXXXX3170. 6. Defendant: made use of said credit card and has a current balance due of $3535.00. 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, MANJUNATH K METI, INDIVIDUALLY, in the amount. of $3535.00 with interest at the statutory rate of 6.00 °s per annum from date of judgment and costs. ~~~~~~~ William T. Molc ,47437 WELTMAN, WEINB & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR# 30068690 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. VERIFICATION ~__.__. c Legal Placement Account Manager (Name) (Title) of DB Servicina 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 nature DB Servicing Corporation serving affiliate MANJUNATH K METI for Discover Bank PO Box 3025 XXXXXXXXXXXX317 0 New Albany, OH 43054 WWR# 30068690 C A Pit SJS - DISCOVER s"o ~ °'°"Ce 30 SDSNBA010014165 MANJUNATH K METI 11 RICHLAND LN APT 112 CAMP HILL PA 17011-2498 Text APP to DISCOV' to receive a link to our free mobile app and pay your bill in seconds from anywhere! PO BOX 6103 ~~~rrr~lrrrrrllrl~rrr~rrrll CAROL STREAM IL 60197-6103 Address,a-mail orielephorrechange? (~~ i~~rnin~~~r~n~ n r~~um~~~~um ~r Innr~~it~tt~~'~;'"~ i~ Go to www,Discover.com or rint than in a above. ~ r r ( ~ ~ ~ ,~' "~^ k P ge spot "~, ~; °, ?! i ~ x 4 OOODD198b623614130578000000000D00000D9800D 1 Opening Dale: September 17, 2012 - Cbsing Date: S Discover More Card Account Summary Account number ending in 3170 Previous Balance 53,535.00 Payments And Credits 3,535.00 Purchases + 0.00 8alancs Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Char ed + 0.00 - New Balance 0,00 See Interest Charge Calculation section fdbwing fransadions For detailed APR information Credit Line $4,500.00 Credit Line Available $0.00 Cash Advance Credit Line $500.00 Cash Advance Credit line Available $0.00 Anniversary Month November Opening Cashback Bonus Baance S 0.00 New Cashback Bonus This Period + 0.00 I Coshback Bonus edenc. $ o.OD I To learn more, log in al vrww.Disoover.com :pbmber 30, 2012 page 1 of 2 Payment Information New Balance $0.00 Minimum Payment Due 2980.00 Payment Due Date October 25, 2012 !ale Payment Warnirg: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35.00 and your purchase and balance transfer APRs For new transactions may be increased up fo the Penalty APR of 23.99% variable. Manage Your Account Online at www.Discover.com Securely access statements and free online tools, pay bills online and track and view all transactions simply and easily Make your money worth more~"1-find easy ways to earn and redeem-cash rewards NEWI Access your account securely through your mobile phone 3 Easy Ways to Contact Us 1 Access your account securely at v~ww.Discov.r.com 2. Call 1-800-DISCOVER (1.800.347.2683). Please have your Dixover®cord available. 3. Write to us at Dixovsr PO Box 30943, Sah Lake City, l1T 841 §0 (Not a payment address) For payments, please send to address on remittance or Dixover PO Box 6103, Carol Stream, IL 60197-6103 For TDD (telecommunications Device For the DeaF) assistance, please call 1.800.347.7449. Transactions Trans. Poet Dab Date Payment wrd Credits Sep 30 Sep 30 INTERNAL CHARGE•OFF $ •3,535.00 fees TOTAL FEES FOR THIS PERIOD $ 0.00 Interest Chorgsd TOTAL R~TEREST FOR THIS PERIOD $ 0.00 2012 Totals Yearto-Date 30068690 Minimum Payment Due ~ Account Number ending in 3170 $980 00 Enter Amount Enclosed Bebw Payment Due Date $ (~_-~ October 25, 2012 TOTAL FEES CHARGED IN 2012 $ 235.00 TOTAL INTEREST CHARGED IN 2012 0.00 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION D'SC~VER ~a ^ - -__ - ~ DISCOVER` Itpaysa MAWUNATH K METI A t b di 3170 i DIS[tp3V ccoun num er en n ER~ __~ g n + page 2 of 2 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rata on your account. Current being Period: 14 days TYPE CtF BALANCE ~~U ERCEFdTAGE 6 ALANCE ECi TO N+ITEREST CHARGE ~i ~ ~ ~~ Purclres.: o.oogo so so Cesh Ad,re~.. 23.99% V so so Balanas Transfers 0.00% SO s0 V =Variable Rate Additional Irrrportent Mormotion Sss your Cerdmembsr Agrwnxnf. Your Cardmember Agreement contains all the terms of your Account. lost or stolen cards. Report immediately) CaN 1-80o-347-2683. Wha- To Do If Yov Think You Ffnd A NYslok~ ors tour Sfofemsnl If you think there is an error on your statement, wrke to us al: Dixowr, PO Box 30421 Sak Lake City, UT 84130A421 In your IeMer, give us the fallowing information: Account information: Your name and account number Dolby amount Tha dollar amount of the suspected error Dsxri ion of Probbm: If you think there is an error on your biN, dsxribs what you believe is wrong and why you believe rt is a mista~- You must contact vs within 60 days sleet the ercor appeared on your statement. You must notify us of any potential errors in w~nti .You may call us, but if you do we are not required fo investigate any pofantial errors and you may have to pay the amount in question. While we investigate whether or not there hoe been an ercor the (dbwing oro hue: We cannot try to collect the amount in question, or report you os delinquent on That amount. The charge in question ma romain on your statement, and we may continue to charge you interest on that amount. Bu-, if we determine that ws made a mistake, you will not have to pay the amount in question or any interest or other Fees related fo that amount. Whib you do not have to pay the amount in question, you oro responsible for the remainder of your balance. We can apply any unpaid amount against your credit limit. Your Rf91rb If You An Dfualfsffoel Wlllt Your CrodH Cord P'urahaaos If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have hied in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purcha». To use this right, all of the following must be true: 1 The purcha» must hwe been made in your home state or within 100 miles of your currant mailing address, and the purchase price must hove been more than s50. (Note: Neither of the» are necessary if your purchase was based on on advertisement we mailed fo you , or if we own the company that sold you the goods or »rvices.) 2. You must have used your credit card for the purcha». Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3. You must not yet haw fully paid for the purcha». If all of the criteria above are met and you ore still dissatisfied with the purchase, contact us in writing ot: Dixover, PO Box 30945, Sak Lake City, UT 84 f 30.0945 While we investigate, the same rules apply to the disputed amount as dixussed above. Aker ws finish our investigation, we will tell you our decision. At that point, if we chink you owe an amount and you do not pay we may report you as delinquent. Payments. You may pay all or port of your Account balance at any time. However, you must pay ar Isast the Minimum Payment Due by the Peymsnf Due Dats. Send only your payment and the top portion of Chia statement in the snvebpe provided. Do not sand cash. BY »nding your check as dexribed show, you authorize us to use information on your check to make an electronic fund transfer From your account at the Financial institution indicated on your check or to process the payment as a check hansaction. If payment rs processed as on electronic fund transfer, the transfer will be for the amount of the check. When we u» information from your check to make an electronic fund transfer, funds ma be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check bock from your financial institution. The processing of your payment may be delayed iF you send cash, correspondence or other items with your payment, if you send the payment to any othx oddrsu or if you u» an enveope other than the one provided. Payments received m pro r form of our processing Facility 6~5PM local time on any day wrll be credited to your Account as of that day. Paymenh ~ received at our processing Facrl after SPM local time will be crediMd fo your Account as of the next day. If you have misplaced your envelope, »nd your payment To Dixover, PO Box 6103 Carol Stream, IL 601 97-6 1 03. f'lea» allow 7~ 10 days for delivery. If your payment rs returned unpaid, ws reserve the rig~t to rewbmit it as an electronic debit. 30068690 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION D'SC~VER WELTMAN,WEINBERG & REIS CO.,L.P.A. BY: William T. Molczan Attorney for Plaintiff(s) I.D.No. 47437 436 Seventh Avenue 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 , Fax: (412) 338-7130 -�' File# 30068690 WTMISJS - 4 CD Discover Bank, Through Its Servicing Agent g g g DB Servicing Corporation Cumberland County Court of Common Pleas -�- vs. � No.: 12-7539 CIVIL MANJUNATH K METI PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above matter without prejudice . WELTMAN, WEINBERG& REIS CO., L.P.A. By 4a- William T. Molczan, Esq e Attorney for Plaintiff 111111 IIIII IIIII IIII 111111 IIIII IIIII IIIII 11111 IIIII IIIII IIII IIIII IIII