HomeMy WebLinkAbout14-1230 30102103 C A Pit SJS
Supreme Court,ofTennSdvania WAXR0
Court of Common Pleas
{ % ' ForProono
thtag Use Only:
Civil Cover,Sheet' ;
C UMBERLANU� `' .,r County Docket No: �h
�.Q
17re information collected on this fibrin is used solely for court administration prnposes. This fornr does not
supplement or replace the filing and service of'pleadings or other papers as rewired by low or rules of court.
Commencement of Action:
S 13 Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Declaration of Takin
DISCOVER BANK
C Lead Plaintiff s Name: Lead Defendant's Name:
'T ELLEN L LAKE
I
C Are money damages requested? 53 Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) 13 outside arbitration limits
Is this a Class Action Suit? ❑ Yes 13 No Is this an MDJ Appeal? ❑ Yes 63 No
A
William T. Molczan,47437
Name of Plaintiff /Appellant's Attorney:
❑ 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 ff 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
❑ Product Liability (does not include ❑ Employment Dispute
E Mass tort) Discrimination
C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
'I' ❑ Other: ❑ Other:
1 ❑ Other:
O
N MASS TORT
❑ Asbestos
B ❑ Tobacco REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - DES ❑ 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
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PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
• Dental ❑ Other:
• Legal
❑ Medical
❑ Other Professional:
Updated 1/1/2011
S YLVANIN
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
/-
DISCOVER BANK ✓/� 9v v/
Plaintiff No. V
VS.
COMPLAINT IN CIVIL ACTION
ELLEN L LAKE
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan,47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh PA 15219 -1827
(412) 434 -7955
FAX: 412 - 338 -7130
30102103 C A Pit SJS
{ 123S
3 b� 3 `f
IN THE COURT OF COMMON. PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
= CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
ELLEN L LAKE
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's
account, which is the subject of this litigation.
4. Defendant is an adult individual(s) residing at 706 MUNICIPAL DR
SHIPPENSBURG, PA 17257
S. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX5212.
6. Defendant made use of said credit card and has a current balance
due of $2046.93. 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 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, ELLEN L LAKE, INDIVIDUALLY, in the amount of $2046.93 and
costs.
William T. Molcza 47437
WELTMAN, WEINBERGV& REIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh PA 15219 -1827
(412) 434 -7955
FAX: 412- 338 -7130
WWR# 30102103 C A Pit SJS
DISC VER Discover More Card
Account number ending in 5212
" Open Date: May 5, 2013- Close Date: Jun 4, 2013
Cardmember Since 2002
Page 1 of 4
A CCOUNT SUMMARY P AYMENT INFORMATION
Previous Balance $2,046.93 ! New Balance $2,046.93
Payments and Credits $0.00 Minimum Payment Due $288.D0
Purchases + $0.00 Payment Due Date July 3, 2013
Balance Transfers + $0.00
Cash Advances + $0.00 ` Includes past due amount of: $247.00
Fees Charged + $0.00 Lake Payment Warning: If we do not receive your minimum payment by the
Interest Charged + $0.00 I dote listed above, you may have to pay a late fee of up to $35.00.
New Balance $2,046.93 Minimum Payment Warning: If you make only the minimum payment each
period, you will pay more in interest and it will take you longer to pay off your
See Interest Charge Calculation section following the balance. For example:
Transactions section for detailed APR information
1f ;umokt)atr�Gncstsr�leftbrs Yau rlipcsyclfltr ,Atrd
Credit line 55,500 its thl tssr ande hmorlt 1 Iante avvnnnthrs yingttrtes6:riododf
Credit Line Available $0!tP?/ sta+etnrttrr+pbodt;. za -
Cash Advance Credit Line $2,800 Only the minimum payment 8 years $2,047
Cosh Advance Credit Line Available $0 If you would like information about credit counseling services, call 1-800-347-1121 1 '
You may be able to avoid interest on Purchases.
See reverse for details. I R EWARDS
/ Anniversary Month
y Cashback Bonus® January
Contact Us Discover.com j Opening Balance $ 0.00
1- 800 - 347 -2683 New Cashback Bonus This Period + $ 0.00
Redeemed This Period –S 0.
Cashback Bonus Balance $ 0.00 j
To learn more, log in at Discover.com 1
Make Check payable to Discover NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Please fold on the perforation below, detach and return with your payment
Pay ment wpo n 0 irve �y by Phtsn Account number ending in 5212
1'1eos do t}pt fold, clip nr ogplq . �t�seov:?r.. 1 34r 2683
._._._. ..... _. .._ ...... _ .. _... Minimum Payment Due $288.00
New Balance $2,046.93
Payment Due Date July 3, 2013
_ .............. ....................._:-........................... __ ..... ..... _ ...... ..... _ ............ :_.._ ..........
_.:......._....
ELLEN L LAKE
1847 ORRSTOWN RD Amount enclosed l $
_._ ........ — ......— ......
... _ ........... -- -- ......... i_ ............. __ ............. _ .......
__.:......._.�
SHIPPENSBURG PA 17257 -8808 - - -
PO BOX 71084
CHARLOTTE NC 28272 -1084
301 021033! Internet payments must be received by 5PM ET to be credited as of the same day
Address, e-mail or telephone changed? Note changes on reverse side
0000019864581 71590355020469300212230028800
ELLEN L LAKE Account number ending in 52 12 Open Date: May 5, "201 oe Date: Jun 4, 2013 Page 2 of 4
.......................... . . ...... . ........ .... .. . ........................... .................. . ........ .. . ................ - . ......... . ... - Close n ............ . . ......... . ......... .. . .......... . ............. . . . .......... -
Important information 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
See your Cardmember Agreement. Your Cardmember Agreement contains must ensure that sufficient funds are available in your bank account, and all
all the terms of your Account. transactions must comply with U.S. low.
Lost or stolen cards. Report immediately! Call 1-800-347-2683. You can set automatic payments for (i) statement New Balance, (ii) statement
Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed
What To Do If You Think You Find A Mistake On Your Statement dollar amount, or (iv) Other dollar amount. If your scheduled "Other dollar
If you think there is an error on your statement, write to us at: Discover, PO amount" payment is not enough to cover the Minimum Payment Due as listed
Box 30421, Salt Lake City, LIT 84130 -0421. You must write to us within 60 on your monthly billing statement, your scheduled payment for that month
days after the error appeared on your statement. You may call us, but if you will be increased to cover the Minimum Payment Due. If the scheduled
do we are not required to investigate any potential errors, and you may have payment is greater than the Minimum Payment Due, any excess will be
to pay the amount in question. The Billing Rights Notice further explains your applied in accordance with your Cardmember Agreement. If your scheduled
rights. Please see your Cordmember Agreement or visit payment is greater than the New Balance on your billing statement, that
https : / /discover.com /billingrighis for a copy of this notice. payment will be processed only for the amount of your New Balance. Your
automatic payment amount may be less than the amount indicated on the
Payments. You may pay all or part of your Account balance at anytime. billing statement based on credits or payments after the Close Date.
However, you must pay at least the Minimum Payment Due by the Payment
Due Date. Send only your payment and the bottom portion of this statement If you enroll by phone in our automatic payment service, please fill-in the
in the envelope provided. Do not send cash. If you pay by check, you following blanks below and retain the authorization for your records.
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 Amount: Full Pay 'I i Min Pay U Min Pay+
or to process the payment as a check transaction. If a payment is processed 0 Other Amount $_; Bonk Routing #:
as on electronic hind transfer, the transfer will be for the amount of the Bonk Account #
check. When we use information from your check to make on electronic fund
transfer, funds may be withdrawn from your account as soon as the some Monthly on the El Payment Due Date 01 Close Dole
day we receive your payment, and you will not receive your check back from Day of month (insert date)
your financial institution.
Credit Reporting. We may report information about your Account to credit
The processing of your payment may be delayed if you send cash, bureaus. Late payments, missed payments, or other defaults on your Account
correspondence or other items with your payment, if you send the payment to may be reflected in your credit report. We normally report the status and
any other address or if you use an envelope other than the one provided. payment history of your Account to credit reporting agencies each month. If
Payments received in proper form at our processing facility by 5PM local time you believe that our report is inaccurate or incomplete, please write us at the
on any day will be credited to your Account as of that day. Payments received following address: Discover, PO Box 15316, Wilmington, DE 19850-5316.
at our processing facility after 5PM local time will be credited to your Account- Please include your name, address, home telephone number and Account
as of the next day. If you hove misplaced your envelope, send your payment number.
to Discover, PO Box 6103, Carol Stream, IL 60197.6103, Please allow 7.10
days for delivery. If your payment is returned unpaid, we reserve the right to Paying Interest. Your due date is at least 25 days after the close of each
resubmit it as an electronic debit. Payments mode online or by phone will be billing period. We will not charge you any interest on new purchases if you
credited as of the day of receipt if mode by 5 PM Eastern time. pay your entire balance by the due date each month. We will begin charging
interest on cash advances and balance transfers as of the later of the
You can pay your monthly Minimum Payment Due, or a greater amount that Transaction Date or the first day of the billing period in which the transaction
does not exceed your current Account balance, over the telephone or you can posted to your Account.
setup automatic payments through a customer service representative by
calling 1-800-347-2683. Automatic payments for the billing period shown How We Calculate Interest Charges. We Use the Daily Balance Method
on your statement will be deducted on the Payment Due Date shown on that (including current transactions) to calculate the Balance Subject to Interest
statement, or the next automatic payment date referred to on your statement, Rate. For more information, please call us at 1.800-347-2683
unless you request a recurring payment date (e.g., the 15" day of the month)
that occurs before your Payment Due Date or Close Date. if your scheduled Balance Subject to Interest Rate. Your statement shows a Balance Subject
payment date falls on a weekend or bank holiday, your payment will be io Interest Rate. It shows this for each transaction category. The Balance
processed the business day prior to the weekend or bank holiday. In order to Subject to Interest Rate is the average of the daily balances during the billing
schedule monthly payments by telephone, you will need this statement and period.
your bank account information. You will be asked to provide the lost four (4)
digits of the social security number of the primary borrower. By providing Credit Balances. If your Account has a credit balance, the amount is shown
those numbers as your electronic signature, you will be agreeing to this on the front of your billing statement. A credit balance is money that is owed
authorization to allow us and your bank to deduct each payment you to you. You may make charges against this amount if your Account is open.
owhorize, in the amount selected by you, from your bank account. You also We will send you a refund of any remaining balance of $1.00 or more after
authorize us to initiate debit or credit entries to your bank account, as 6 months, or as otherwise required by applicable low, or upon request made
applicable, to correct an error in the processing of such payment. You can to the address in the Contact Us section on page 3 of your billing statement.
cancel a scheduled payment by phone at 1-800-347-2683 or by mail at Discover may monitor and/or record telephone calls between you and
Discover, PO Box 30421, Salt Lake City, LIT 84130 -0421; however, we must Discover representatives for quality assurance purposes.
receive notice at least three business days in advance of the scheduled The Discover(I card is issued by Discover Bank, Member FDIC. TL9-22NF
payment.
CHANGE OF ADDRESS
If correct on front, do not use. Please print clearly in blue or black ink, in the space provided.
Street Address I Home Phone
. . ......... . . ..... ---------
Work Phone
. ........ . ............... . .. . ..... .................. . . ............ . ..................... . ..... . .. . ..... . ................... . . . ............. . .......... L ........... . . ................................................. . . . . .............................. . . ........ . . . . ......... ... .............................
City Email
I 361bi'103
To make changes to your address, email or telephone number, visit Discover.com
Continued on next page
Discover More Card".',.
D ISC VER Account number ending in 5212
Open Date: May 5, 2013 - Close Dote: Jun 4, 2013
— - ..... _. _... -- - T Page 3 of 4
CONTACT CT US
..-------- .------- ......._ .. ............_._.... _.._._....._ ........_.....__._................_..........._................_.... .....__...........__....._..... _........................__ .__.................. __...._....._ ._....... _ ....
__........__....._........._......._.........--
0 Web AM Mobile Phone ® Inquiry Mail Payments
Access your Manage your 1- 800 - DISCOVER Discover Discover
account securely account anytime, (1- 800 - 347 -2683) PO Box 30943 PO Box 6103
at Discover.com anywhere of TDD 1- 800 - 347 -7449 Salt Lake City Carol Stream
m _ _ _ _ _ UT 84130 _ IL 60197 -6103
Transactions
Trans. Date Post Date
....... __ ..... -- .......... - _ ......... _..- -- ........... _.._...._._ ........ _ .......... ._ ........ __..........__........--- .......... -- ........... _ .............. __ ......... _ ................. _ .............. _- ........ _ ............ _ .............. --- ...... _ ....... _ ............ _._ ..... _.. ........................................... _ ............... _ ............ _ ...... __.._ ..... _ ....... __ ............. --
Fees TO TAL FEES FOR T HIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
2013 Totals Year -to -Date
TOTAL FEES CHARGED IN 2013 $ 0.00
TOTAL INTEREST CHARGED IN 2013 $ 24.32
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current Billing Period: 31 days
ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO
TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE
Purchases 6.99% $0.00 WOO
Cash Advances 6.99% $0.00 $0.00
V= Variable Rate
Information For You
For more information about how interest charges are calculated see your Cardmember Agreement or go to www .discover.com /interestchorges
30102103
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
ELLEN L LAKE Accdtjrii number endinq'in.521 2 Open Date: May 5, 2013 _Close Dote: Jun 4, 2013 ........ ..... Page 4 of 4
.......... . ....... .... ......... . ......... . ....... ..... . ................. . ....... . ........ . ..... . ...... ...... .. . ...............
301021011
DISC VER Discover More Card
Account number ending in 5212
Open Date: Apr 5, 2013- Close Date: May 4, 2013
Cordmember Since 2002
Page 1 of 4
A CCOUNT SUMMARY P AYMENT INFORMATION
i r `)
Previous Balance $2,046.93 ' New Balance $2,046.93
I Payments and Credits — $0.00 Minimum Payment Due $247.00
Purchases + $0.00 Payment Due Date June 3, 2013
Balance Transfers + $0.00 • Includes post due amount of: $206.00
1 Cash Advances + $0.00
Fees Charged + $0.00 Late Payment Warning: If we do not receive your minimum payment by the
'i Interest Charged + $0.00 j date listed above, you may have to pay a late fee of up to $35.00_
New Balance $2,046.93 s Minimum Payment Warning: If you make only the minimum payment each
period, you will pay more in interest and it will take you longer to pay off your
See Interest Charge Calculation section following the balance. For example:
Transactions section for detailed APR information
Credit Line 55,500
If Inctk ta�.addtnratl2rtges Yot,wll, pay oEfhe. And. t3?td up
�rsing thtk�ot;*f pond each ttaorNli ; bolafice 5ti6�rq opt tars �ying,on es� r�ated'fc>taf
Credit Line Available $ 0?� }?�!y:r.,taletnitinolapul. of
Cash Advance Credit Line $2,800
Only the minimum a ment 8 ears $2,047
i Cash Advance Credit Line Available $0 If you would like information about credit counseling services, call 1-800-347-1121 J
You may be able to avoid interest on Purchases.
See reverse for details. R EWARDS
L J
Cashback BonusO Anniversary Month l
January
Contact Us Discover.com Opening Balance $ 0.00
1- 800 -347 -2683 i New Cashback Bonus This Period + S 0.00
- -- -� Redeemed This Period _ _ _ _ _ — $ _0.
Cashback Bonus Balance $ 0.00
To - learn more, log in at Discover.com
Make Check payable io Discover NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Please fold on the perforation below, detach and return with your payment
�q tneht oU} t1 0 . Ptfy 0"11150 fd by f � Account number ending in 5212
€x1as.cr ttat f4(d clip sitgPle ;. i 3 COVer. am f'634 -i!a83 Minimum Payment Due $247.00
New Balance $2,046.93
Payment Due Date June 3, 2013
_ ........... .. ................................ _.: .......................................... _..: ....... ................................................................... __..
ELLEN L LAKE Amount enclosed $
1847 ORRSTOWN RD
.._ .......... -- ........ ._ ...... --- ............. ............. _.._.— ... _ .... _.- ............ _............ _ ........... _ ........
�
SHIPPENSBURG PA 17257 -8808
PO BOX 71084
CHARLOTTE NC 28272 -1084
301 0irW3d Intemet payments must be received by 5PM Elio be credited as of the same day
Address, e-mail or telephone changed? Note changes on reverse side
000001986458171590355020469300027740024700
ELLEN L LAKE Account number ending in 5212._ ..........._.._..........._Open Date: Apr 5, 2Q13 -Close Dote: May 4, 2013 . _._.__..— _......._ Page 2 of 4
Important Information. 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
See your Cardmember Agreement. Your Cardmember Agreement contains must ensure that sufficient funds are available in your bank account, and all
all the terms of your Account. transactions must comply with U.S. law.
Lost or stolen cards. Report immediately) Call 1- 800 - 347 -2683. You can set automatic paymenis.for. (i) statement New Balance, (ii) statement
Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed
What To Do If You Think You Find A Mistake On Your Statement dollar amount, or (iv) Other dollar amount. If your scheduled "Other dollar
If you think there is an error on your statement, write to us at: Discover, PO amount" payment is not enough to cover the Minimum Payment Due as listed
Box 30421, Solt Lake City, UT 84130 -0421. You must write to us within 60 on your monthly billing statement, your scheduled payment for that month
days after the error appeared on your statement. You may call us, but if you will be increased to cover the Minimum Payment Due. If the scheduled
do we are not required to investigate any potential errors, and you may have payment is greater than the Minimum Payment Due, any excess will be
to pay the amount in question. The Billing Rights Notice further explains your applied in accordance with your Card member Agreement. If your scheduled
rights. Please see your Cordmember Agreement or visit payment is greater than the New Balance on your billing statement, that
https : / /discover.com /billingrights for a copy of this notice. payment will be processed only for the amount of your New Balance.. Your
automatic payment amount may be less than the amount indicated on the
Payments. You may pay all or part of your Account balance at anytime. billing statement based on credits or payments after the Close Date.
However, you must pay at least the Minimum Payment Due by the Payment If you enroll by phone in our automatic payment service, please fill - in the
Due Date. Send only your payment and the bottom portion of this statement
in the envelope provided. Do not send cash. If you pay by check, you following blanks below and retain the authorization for your records.
authorize us to use information on your check to make an electronic fund Amount: [_] Full Pay l._j Min Pay D Mi n Pay+ $
transfer from your account at the financial institution indicated on your check
or to process the payment as a check transaction. If a payment is processed D Other Amount $ ; Bank Routing #:
as on electronic fund transfer, the transfer will be for the amount of the Bank Account # ;
check. When we use information from your check to make on electronic fund
transfer, funds may be withdrawn from your account as soon as the some Monthly on the 0 Payment Due Date U Close Date
day we receive your payment, and you will not receive your check back from Q Day of month (insert date)
your financial institution.
The processing of your payment may be delayed if you send cash, Credit Reporting. We may report information about your Account to credit
bureaus. Late payments, missed payments, or other defaults on your Account
correspondence or other items with your payment, if you send the payment to may be reflected in your credit report. We normally report the status and
any other address or if you use an envelope other than the one provided. payment history of your Account to credit reporting agencies each month. If
Payments received in proper form at our processing facility by 5PM local time you believe that our report is inaccurate or incomplete, please write us at the
on any day will be credited to your Account as of that day. Payments received following address: Discover, PO Box 15316, Wilmington, DE 19850 -5316.
at our processing facility after 5PM local time will be credited to your Account Please include your name, address, home telephone number and Account
as of the next day. If you have misplaced your envelope, send your payment number.
to Discover, PO Box 6103, Carol Stream, IL 60197.6103. Please allow 7.10
days for delivery. If your payment is returned unpaid, we reserve the right to Paying Interest. Your due date is at least 25 days after the close of each
resubmit it as an electronic debit. Payments made online or by phone will be billing period. We will not charge you any interest on new purchases if you
credited as of the day of receipt if mode by 5 PM Eastern time. pay your entire balance by the due date each month. We will begin charging
a our month) Minimum P a y ment Due, or o renter amount that interest on cash advances and balance transfers as of the later of the
You can
p ay Y Y 9 Transaction Date or the first day of the billing period in which the transaction
does not exceed your current Account balance, over the telephone or you can posted to your Account.
setup automatic payments through a customer service representative by
calling 1- 800 - 347 -2683. Automatic payments for the billing period shown How We Calculate Interest Charges. We Use the Daily Balance Method
on your statement will be deducted on the Payment Due Date shown on that (including current transactions) to calculate the Balance Subject to Interest
statement, or the next automatic payment date referred to on your statement, Rate. For more information, please call us at 1- 800 - 347 -2683
unless you request a recurring poyment date (e.g., the 15'' day of the month)
that occurs before your Payment Due Date or Close Date. If your scheduled Balance Subject to Interest Rate. Your statement shows a Balance Subject
payment date falls on a weekend or bank holiday, your payment will be to Interest Rate. It shows this for each transaction category. The Balance
processed the business day prior to the weekend or bank holiday. In order to Subject to Interest Rate is the average of the daily balances during the billing
schedule monthly payments by telephone, you will need this statement and period.
your bank account information. You will be asked to provide the lost four (4)
digits of the social security number of the primary borrower. By providing Credit Balances. If your Account has a credit balance, the amount is shown
those numbers as your electronic signature, you will be agreeing to this on the front of your billing statement. A credit balance is money that is owed
authorization to allow us and your bank to deduct each payment you to you. You may make charges against this amount if your Account is open,
authorize, in the amount selected by you, from your bank account. You also We will send you a refund of any remaining balance of $1.00 or more after
authorize us to initiate debit or credit entries to your bank account, as 6 months, or as otherwise required by applicable low, or upon request made
applicable, to correct an error in the processing of such payment. You can to the address in the Contact Us section on page 3 of your billing statement.
cancel a scheduled payment by phone at 1 -800- 347 -2683 or by mail at Discover may monitor and /or record telephone calls between you and
Discover, PO Box 30421, Salt Lake City, UT 84130 -0421; however, we must Discover representatives for quality assurance purposes.
receive notice at least three business days in advance of the scheduled The Discover(9 card is issued by Discover Bank, Member FDIC. TL9 -22NF
payment.
CHANGE OF ADDRESS
If correct on front, do not use. Please print clearly in blue or black ink, in the space provided.
Street Address Home Phone
Work Phone
City Email
l
36 bR03 F � - - --
To make changes to your address, email or telephone number, visit Discover.com
Continued on next page
DISC VEK Discover More Card
Account number ending in 5212
Open Date: Apr 5, 2013 - Close Date: May 4, 2013
Page 3 of 4
CONTACT - - , US
0 Web Mobile Phone Inquiry Mail Payments
Access your Manage your 1-800-DISCOVER Discover Discover
account securely account anytime, (1-800-347-2683) PO Box 30943 PO Box 6103
of Discover.corn anywhere at TDD 1-800-347-7449
Solt Lake City Carol Stream
m.Discover.com LIT 84130 IL 60197-6103
Transactions
Trans. Date Post Date
.......... . ........ . .. . .......... . . ........ . . . . ....... . ........................... —.- . . . ........ . ................ . ............................. . . ........ . ........................................... . . ................................................ . .............. . . . . .. . .................... . ....... . ..... . . ......... . ................... . ..... . . ............. . ........ . . .............
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD s 0.00
2013 Totals Year-to-Date
TOTAL FEES CHARGED IN 2013 $ 0.00
TOTAL INTEREST CHARGED IN 2013 S 24.32
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current Billing Period: 30 days
ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO
TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE
Purchases 6.99% $0.00 $0.00
Cash Advances 6.99% $0.00 $0.00
V=Voriable Rate
Information For You
For more information about how interest charges are calculated see your Cordmember Agreement or gotowwvv.discover.com/interesicharges
30102101
NOTICE- SEE REVERSE SIDE FOR IMPORTANT INFORMATION
E..LLEN u
L LAKE Accont number ending in 5212
- - ---- . . . ..... .... . . ............ . . . ........... . .... . . ............... . ..... . . ..... . ... Open Date: Apr 5, 2013 _Close Date: May 4, 201 3 ......._......... Page 4 f 4
.....— _...._...._....pen ......... . . ..... .
.... o
. . ......... ......... Page . ........... . . . ....
3010210Z"
VERIFICATION
(Ne) . le)
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 unswom 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
DB Servicing Corporation servicing affiliate
For Discover Bank
. . ,
=
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Matthew D. Urban
I.D. No. 90963
436 7th Ave Ste 1400
Pittsburgh, PA 15219
Phone: (412) 434-7955
Fax: (412) 338-7130
File # 30102103 MDU/S.IS
Attorney for Plaintiff(s)
DISCOVER BANK Cumberland County
Court of Common Pleas
vs.
No.: 14-1230 CIVIL
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
ELLEN L LAKE
Kindly dismiss the above matter without prejudice.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Matthew D. Urban, Esquire
Attorney for Plaintiff
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