HomeMy WebLinkAbout13-3465 Supreme Court;n Pennsv1vania NYWR# 30067095 C A Pit SJS
Cou °of Common F-Jeas
j w V1
Clv& ver Sheet For ProtGonotan' Use Onl} :
u
C UMBERLAND Counh, Docket No: 1
P ❑
I�.3��5
Tire in rination collected on this form is used solell, for court administration purposes. This form does not ' fo
supplement or replace the filing and service of pleadings or other papers as required by lau or rules of court.
Commencement of Action:
S a Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Declaration of Takin
C DISCOVER BANK
Lead Plaintiff's Name: Lead Defendant's Name:
T DAVID W BOYER
I
0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? ❑ Yes 13 No Is this an MDJ Appeal? ❑ Yes W No
Name of Plaintiff /Appellant's Attorney: William T. Molczan,47437
❑ Check here if you have no attorney (are a Self- Represented (Pro Sel Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional Buyer Protection Administrative Agencies
❑ Malicious Prosecution Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Statutory Appeal: Other
E
E3 Product Liability (does not include [3 Employment Dispute
Mass tort) Discrimination
C ❑ Slander /Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other: ❑ Other:
I ❑ Other:
O
N MASS TORT
❑ Asbestos
B ❑ Tobacco REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - DES 13 Ejectment ❑ Common Law /Statutory Arbitration
❑ Toxic Tort — Implant ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Toxic Waste ❑ Ground Rent ❑ Mandamus
❑ Other: ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure: Residential Retraining Order
❑ Mortgage Foreclosure: Commercial ❑ Quo Waranto
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
Updated 1/1/2011
NOTICE
Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part:
Rule 205.5. Cover Sheet
(a)(1) This rule shall apply to all actions governed by the rules of civil procedure except the
following:
(i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq.
actions for support, Rules 1910.1 et seq.
actions for custody, partial custody and visitation of minor children, Rules
1915.1 et seq.
(iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq.
(v) actions in domestic relations generally, including paternity actions, Rules
193 0. 1 et seq.
(vi) voluntary mediation in custody actions, Rules 1940.1 et seq.
(2) At the commencement of any action, the party initiating the action shall complete
the cover sheet set forth in subdivision (e) and file it with the prothonotary.
(b) The prothonotary shall not accept a filing commencing an action without a
completed cover sheet.
(c) The prothonotary shall assist a party appearing pro se in the completion of the form.
(d) A judicial district which has implemented an electronic filing system pursuant to
Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the
provisions of this rule.
(e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural
Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be
published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us.
OF T1 PROTHONYTAR)"
2013 JUN 17 FM 1 16
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK /
vs. Plaintiff No
3
v
COMPLAINT IN CIVIL ACTION
DAVID W BOYER
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
30067095 C A Pit SJS
s
0
��
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
DAVID W BOYER
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 611 B ST ENOLA, PA
17025
5. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX4919.
6. Defendant made use of said credit card and has a current balance
due of $6562.61. A copy of Plaintiff's STATEMENT is attached hereto,
marked as Exhibit
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 repeatedly 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, DAVID W BOYER, INDIVIDUALLY, in the amount of $6562.61 with
interest at the statutory rate of 6.00 o per annum from date of
judgment and costs.
William T. M czan,4 437
WELTMAN, WEINBERG EIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412- 338 -7130
WWR## 30067095 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.
New Balance Minimum Payment Due Account Number ending in 4919
DISCOVER
$6,562.61 $488.00 Enter Amount Enclosed Below
Payment Due Date
October 2, 2012
Please make check pa yable to Discover Card.
You are overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
05 SDSN6A010000434 $362.61
DAVID W BOYER Text APP to OISCOV' to receive a link to our
611 B ST free mobile app and pay your bill in seconds
ENOLA PA 17025 -1602 from anywherel
PO BOX 71084 Illeulln�llnnlslnlrl�l
CHARLOTTE NC 28272 -1084
Address, e-mail or telephone change? lul�llnln�lrllurinlrlu�llllu�lnlnlnllulnlnl�lnll
Go to www.Discover.com or print change in space above.
0000019864587467 68411065626100000000048800
Opening Date: August 6, 2012 - Closing Date: September 5, 2012 page 1 of 2
Discover More Card Account Summary Payment Information
New Balance $6,562.61
Minimum Payment Due' $488.00
Account number ending in 4919
Payment Due Date October 2, 2012
Previous Balance $6,378.59 'Includes past due amount of $323.00
Payments And Credits 0
Purchases + 0.00 Late Payment Warning: If we do not receive your minimum
Balance Transfers + 0 payment by the date listed above, you may have to pay a late
Cash Advances + 000 fee of up to $35.00 and your purchase and balance transfer
Fees Charged + 35.00 APRs for new transactions may be increased up to the Penalty
Interest Charged + 149.02 APR of 25.24% variable.
New Balance 562.61
Minimum Payment Warning: If you make only the minimum
See Interest Charge Calculation section following payment each period, you will pay more in interest and it will
transactions for detailed APR information take you longer to pay off your balance. For example:
Credit Line
00.00 tyow nto a no . Yaq vnll poyoFf:)hs And yov rYd :end::
Ciedif line Available $0.00' d'to�ai
<. fancy sha�vti a(i[: ,iip }aytnar;,,
Cash Advance Credit Line $3,100.00 "(/t8;;tht3 4ar�l told fbu�'afwtemtszit id �stjin4t� trite): t>!• ,
Cash Advance Credit line Available
$0.00 fif °..; gE�t1(�:.:.,,:::...
You may be able to avoid Interest Charges, see Additional Only the minimum 44 years $38,122
Important Information for details. payment
IF you would like information about credit counseling services,
Cashback Bonus° Anniversary Month call 1- 800 - 347.1121
March
Opening Cashback Bonus Balance $ 0.00
New Coshback Bonus This Period + 0.00
Cashback Bonus Balance $ 0.00
10 team more, log in ai www- Oiscover.com
3 Easy Ways to Contact Us Manage Your Account Online at www.Discover.com
1 Access your account securely at www.Disco"r.com Access free online tools like Paydown Planner to create a plan
2. Call 1. 800 - DISCOVER (1- 800 - 347.2683. to P a y down your balance, securely access statements, pay
Please have your Discovere card avoila e. bills online and easily track all transactions
3. Write to us at Discover -PO Box 30943,
Soft lake City, UT 841 i 30 (Not a payment address) Make your money worth morel —Find easy ways to cam
For payments, please send to address on remittance or and redeem cash rewards
Discover, PO Box 6103, Carol Stream, IL 60197 -6103 NEWT Access your account securely through your
For TDD (Telecommunications Device for the Deaf) mobile phone
assistance, Please call 1- 800 - 347.7449.
U@U WNjpns Trans. Post
Date Date
Fees Sep 2 Sep 2 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD $ 0.60 EXHIBIT
ln*°st Charged INTEREST CHARGE ON PURCHASES
INTEREST CHARGE ON CASH ADVANCES 148.41 1
INTEREST CHARGE ON BALANCE TRANSFERS 0,00 J
I
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISC
Paperless statements mean less clutter, more convenience
Easily access up to 24 months of downloadable, password protected statements.
• See your statement as soon as it's available rather than wait for it to arrive in your mailbox.
• Get helpful payment reminders through e-mail or text messages on your mobile phone.
• Print a paper copy of your statement anytime.
• Sign up today at Discovercom /paperless
®2010 Discover Bank, Member FDIC PAPER.0310
Transactions cn
Trans. Post Z
(cont.) Date Date o
0
0
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 149.02 w
A
2012 Totals Year -to -Date
TOTAL FEES CHARGED IN 2012 $ 105.00
TOTAL INTEREST CHARGED IN 2012 1,232.38
30067095
Questions? Visit www.Discover.com or
call 1 -800- DISCOVER (1.800- 347 - 2683), DISCOVER
DISCOVER It pays to DAVID W BOYER
DMOY-t:R• Account number ending in 4919
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current Billing Period: 31 days
TYPE OF BALANCE ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE
Purchases RATE (APR) INTEREST RATE
Cash ores Advances 20.24% V $35.64 $0.61
27.24% V $6,414.77 $148.41
V - Variable Rate
Information For You
"Discover Home loans State Licensing Info** Not all applicants are approved. Terms and conditions apply. AZ
Mortgage Banker UC No. 0919392; Licensed by the Dept of Corporations under the CA Residential Mortgage Lending Act;
Regulated by the CO Division of Real Estate; GA Residential Mortgage Licensee #33265; IL Residential Mortgage Licensee
#MB.6760852 -Dept of Financial Regulation, 100 W Randolph, 9th Floor, Chicago, IL 60601 MA Mortgage Lender &
Mortgage Broker UC #MC837915; licensed by the MS Dept of Banking and Consumer Finance; Licensed by the NH
Banking Dept; N) Residential Mortgage lender UC; OH Mortgage Broker Act Mortgage Banker Exemption
#MBMB.850150.000; OR Mortgage lender LIC #ML -5100; Licensed by the PA Dept of Banking; VA Exempt Company -
Registration; Licensed in WA under the name of DFS HL Inc. Consumer Loan UC #CL- 837915; Discover Home Loans, Inc.'s
NMIS #837915. Not available in NV, NY & RI
Additional Important Information
See your Cardmembor Agreement. Your Cardmember Agreement contains all the terms of your Account.
Lost or stolen cards. Report immediatelyl Call 1400.347 -2683.
What To Do if You Think You Find A Mistake On Your Statement
If you think there is an error on your statement, write to us at: Discover. PO Box 30421 Sah Lake City, UT 84130.0421
In your letter give us the Following information:
Account information: Your name and account number
Dollar amount: The dollar amount of the suspected error.
Descri Pion of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe
t is a mistake.
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writing. You may call us, but if you do we are not required to investigate any
potential errors and you may have to pay the amount in question.
While we investigate whether or not there has been an error, the following are true:
We cannot try to collect the amount in question, or report you as delinquent on that amount.
The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if
we determine that we made a mistake, you will not have to pay the amount in question or any interest or other Fees related
to that amount.
While you do not have to pay the amount in question, you are responsible for the remainder of your balance.
We can apply any unpaid amount against your credit limit.
Your Riahts if You Are Dissatisfied With Your Credit Card Purchases
If you ore dissatisfied with the goods or services that you have purchased with your credit card, and you have tried
in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount
due on the purchase.
To use this right, all of the Following must be true:
1 The purchase must have been made in your home state or within 100 miles of your current moiling address, and
the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was
based on an advertisement we mailed to you , or if we own the company that sold you the goods or services.)
2. You must have used your credit card for the purchase. 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 have fully paid for the purchase.
If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writin at:
Discover. PO Box 30945, Soft Lake City, UT 84130 -0945 g
While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our
investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we
may report you as delinquent.
Payments. You may pay all or part of your Account balance at any time. However, you must pay at least the Minimum
Payment Due by the Payment Due Date. Send only your payment and the top portion of this statement in the envelope
provided. Do not send cash. By sending your check as described above, 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 transaction. IF pa ent 4- processed 03- an electronic fund transfer, -the transfer will be for the amount of-
the check. When we use information from your check to make an electronic Fund transfer, funds may be withdrawn from your
account as soon as the some day we receive your payment, and you will not receive your check back from your financial
institution.
The processing of your payment maybe delayed if you send cash, correspondence or other items with your poyment, if you
send the payment o any other address or if you use an envelope other than the one provided. Payments received in proper
form of our processing Facility b SPM local time on any d will be credited to our Account
received at our processing facility after 5PM local time will lb y as o that day. Payments
f
e credited to your Account as of she next day. If you hove
�i �,��C envelope, send your payment to Discover PO Box 6103 Carol Stream, IL 60197.6103. Please allow 7.10
a OY. If your payment is returned unpaid, we reserve the rig t to resubmit it as an electronic debit.
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISC *VER
You can pay your monthly Minimum Payment Due, or a greater amount that does not exceed your current Account balance,
over the telephone or you can setup automatic payments through a customer service representative by calling
1- 800- 347 -2683. Automatic payments will be deducted on the Payment Due Dote unless you request a recurring pa ent
date e.g. the 15th day of the month that occurs before your Payment Due Date. If your scheduled payment date falls on a
weekend or bank holidoy, your payment will be processed the business day rior to the weekend or bank holiday. In order
to schedule monthly payments b telephone, you will need this statement and bank account information. You will be
asked to provide the last four (4rdigit3 of the social security number of the primary borrower. By de roviding those numbers as
your electronic signature, you will be agreeing to this authorization to allow us and your bank to duct each payment you
authorize, in the amount selected by you, from your bank account. You also authorize us to initiate debit or credit entries to
your bank account, as applicable, to correct an error in the processing of such payment. You can cancel a scheduled
payment by phone at 1- 800347.2683 or by mail at Discover, PO Box 30421 Sall Lake City, UT 84130-042 1, however we
must receive notice at least three business days in advance of the scheduled payment. If your payments may vary in amount,
we will tell you on each monthly billing statement when your payment will be made and how much it will be. You must ensure
that sufficient funds are available in your bank account, and all transactions must comply with U.S. law.
You can set automatic payments for (i) statement New Balance, (ii) statement Minimum Payment Due, (iii) statement Minimum
Payment Due plus a fixed dollar amount, or (iv) a fixed dollar amount. If your scheduled fixed payment is not enouggh to cover
the Minimum Payment Due as listed on your monthly billing statement, your scheduled payment for that month will be
increased to cover the Minimum Payment Due. If the scheduled payment is greater than the Minimum Payment Due, any
excess will be applied in accordance with your Cardmember Agreement. IF your scheduled payment is greater than the New
Balance on your billin g statement, that payment will be processed only for the amount of your New Balance. Your automatic
payment amount maybe less than the amount indicated on the periodic statement based on credits or payments after the
Closing Date.
If you enroll by phone in our automatic payment service, please fill -ir, the following blanks below and retain the authorization
for your records.
Amount: ❑ Full Pay ❑ Min Pay ❑ Min Pay + $ ❑ Fixed Pay$ m
Bank Routing #: Bank Account #: Frequency: En
Z
Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed payments, or a
other defoulfs on your Account may be reflected in your credit report. We normally report the status and payment history of °
your Account to credit reporting agencies each month. If ou believe that our report is inaccurate or incomplete, please write g
us at the following address: Discover PO Box 15316, Wilmington, DE 198505316. Please indicate your name, address,
home telephone number and Account number. w
Paying Interest. We begin to impose interest charges on a transaction, fee or interest charge from the day we add it to the m
dally bolonce. We continue to impose interest charges until you pay the total amount you owe us. You can avoid Paying
interest on Purchases as described below. However. you cannot avoid paying interest on Balance Transfers or Cash
Advances.
How to Avoid Payinq Interest on Purchases Grace Period"
you paid the New balance on your previous billing statement by the Payment Due Date shown on that billing statement, we
will not impose interest charges on new Purchases or any portion of a new Purchase, paid by the Payment Due Date on your
current billing statement. New Purchases are Purchases that first appear on the current billing statement.
How We Apply Payments Ma Im cf Your G
ou race Period
y o not pay your era a once in eac month, then, depending on the balance to which we apply your payment,
you may not get a grace period on new Purchases.
How We Calculate Interest Charges Daily balance Method (including current transactions): We calculate interest charges
each billing period by first figuring the "doily balance" for each Transaction Category. Transaction Categories include
standard Purchases, standard Cash Advances and different promotional balances, such as Balance Transfers.
How We Figure the Daily Balance for Each Transaction Category
We start with the beginning balance For each day. The b inning balance for the First day of the billing period is
your balance on the fast day of your previous billing pert
We add any interest charges accrued on the previous day's daily balance and any new transactions and fees. We
add any new transactions or fees as of the later of the Transaction Date or the first day of the billing period in
which the transaction or fee posted to your Account.
We subtract any new credits and payments.
We make other adjustments (including those adjustments required in the "Paying Interest" section).
How We Figure Your Total Interest Charges
We multiply the daily balance for each Transaction Category by its daily periodic rate. We do this for each day in
the billing period. This gives us the interest charges for each Transaction Category. To get a daily periodic rate,
we divide the APR that applies to the Transaction Category by 365.
We add up all the daily interest charges. The sum is the total interest charge for the billing period.
Now We Include Fees
We add Balance Transfer Fees to the applicable Balance Transfer Transaction Category. We add Cash Advance
Fees to the applicable Cash Advance Transaction Category. We add all other fees to the standard Purchase
Transaction Category.
Balance Subject to InIerest Rate. Your statement shows a Balance Subject to Interest Rate. It shows this for each
transaction category. The Balance Subject to Interest Rate is the average of the daily balances during the billing
period.
Credit Balances. If your Account has a credit balance, the amount is shown on the Front of your billing statement.
A credit balance is money that is owed to you. You may make charges against this amount if your Account is
open. We will send you a refund of any remaining balance of $1.00 or more after 6 months, or as otherwise
required by applicable law.
For TDD (Telecommunications Device for the Deaf) assistance, please call 1.800-347 -7449.
u
*
pw mitor and /or record telephone calls between you and Discover representatives for quality assurance
u
The Discover ® card is issued by Discover Bank, Member FDIC RZNFE0a1
Questions? Visit www.Discover.com or
call 1 .800- DISCOVER (1.800 -347- 2683). DISCOVER
VERIFICATION
(Name) (T I
of DB Servicing Corporation, servicing affiliate of Discover Bank 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. Additionally, he /she verifies that
Discover Bank, f /k /a Greenwood Trust Company, which is an. FDIC - insured Delaware state bank, lacks
sufficient knowledge or information to verify this complaint. He /she verifies that he /she is authorized to
make this verification. As an employee of DB Servicing Corporation, he /she has sufficient knowledge
and information to make this verification, and consequently verifies that the facts set forth in the
foregoing complaint are true and correct 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.
It is further stated that Discover Bank and DB Servicing Corporation extend 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
(Si ature)
DB Servicing Corporation servicing affiliate
For Discover Bank
PO Box 3025
New Albany, OH 43054
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson t-11LE D-0F1 !CE
Sheriff , a e°wrat�tar, OF THE PROTHONOTAR
Jody S Smith 2013 JUN 28 AM 10: 1 t
Chief Deputy
Richard W Stewart �=° �x CUMBERLAND COUNTY
Solicitor OFjF CC;OF T4 S�,t,'RfF PENNSYLVANIA
Discover Bank Case Number
vs. 2013-3465
David Wayne Boyer
SHERIFF'S RETURN OF SERVICE
06/19/2013 08:43 PM- Deputy Tim Black, 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: David Wayne Boyer at 611 B Street, East Pennsboro, Enola, PA 17025.
`�, .e—
TIM B C , DEPUTY
SHERIFF COST: $44.95 SO ANSWERS,
June 21, 2013 RbNW R ANDERSON, SHERIFF
(c)GountyS,uite Sheriff,Teleosoft,Inc.
J" TJ�J". PROTHONOTA '�
2013 AUG -5 PH 1: �01
WELTMAN, WEINBERG & REIS CRS r MAND 000_ N T Y
BY: James C Warmbrodt l'E N N S Y LVA N I PAttorney for PIaintiff(s)
I.D. No. 42524
436 Seventh Avenue 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412)434-7955
Fax: (412) 338-7130
File# 30067095 WTMISJS
DISCOVER BANK Cumberland County
Court of Common Pleas
vs.
No.: 13-3465 CIVIL
DAVID W BOYER
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss the above matter without prejudice .
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
James C brodt, Esquire
Attorney f r Plaintiff
111111 IIIII IIIII IIII 111111 IIIII IIIII IIIII IIIII IIIII IIIII IIII IIIII IIII