HomeMy WebLinkAbout14-4403 f
Supreme Court "�i� -KVeas
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CUMBERLAN :�� ICounty Docket No:
14- 44thivilTe m
I7re information collected on this form is used solely for court administration purposes. 117is form does not
supplemenf or replace the filing acrd sen„ice ofpleodirags or other popers as required big laiv or rules of court.
Commencement of Action:
13 Complaint [3 ;Writ of Summons [3 Petition
I ,.S Transfer from Another Jurisdiction Declaration of Taking
is
'`' DISCOVER BANK
C ” Lead Plaintiff's Name: Lead Defendant's Name:
JANINE M FOOSE
Are money damages requested? El Yes ❑ No Dollar Amount Requested: El within arbitration limits
..0.;: (check one) ❑ outside arbitration limits
Is this a Class Action Suit? ❑ Yes [q No Is this an AMJ Appeal? ❑ Yes W No
A
William T. Molczan, 47437
Name of Plaintiff/Appellant's Attorney:
❑ Check here if you have no attorney are a Self-Represented Pro Se'l 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.
s.:.
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 p Dept. of Transportation
[3 Premises Liability ❑ Statutory Appeal:Other
13Product Liability(does notinclude ❑ Employment Dispute
Mass tort) Discrimination
"C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
;T ❑ Other: ❑ Other:
"` ❑ Other:
0:
N MASS TORT
❑ Asbestos —
°; ❑ 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: ❑tLandlordlTenant Dispute ❑ Non-Domestic Relations
❑ Mortgage Foreclosure:Residential Retraining Order
❑ Mortgage Foreclosure:Commercial ❑ QGo Waranto
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY '❑ Quiet Title ' ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑. Medical
❑ Other Professional:
Updated 1/1/2011
_ FILEC-OFFICE
f
CIF T HE PRO T I'IV�'�OVdR�l
2014 JUL 28 AM 11: 40
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: %05 0110Tem
VS .
COMPLAINT IN CIVIL ACTION
JANINE M FOOSE
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
30334241 C A Pit SJS
0
f 3.'75 PO ATr'-1
c �i131993`1r&78380
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
JANINE M FOOSE
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 317 JUNIPER ST
CARLISLE, PA 17013
5 . Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX6066 .
6 . Defendant made use of said credit card and has a current balance
due of $13835 . 05 . A copy of Plaintiff ' s STATEMENT is attached hereto,
marked as Exhibit 11111 .
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, JANINE M FOOSE, INDIVIDUALLY, in the amount of $13835 . 05
and costs .
William T. Molcz , 47437
WELTMAN, WEINBEW & REIS CO. , L.P.A.
436 7th Ave Ste 1400
Pittsburgh PA 15219-1827
(412) 434-7955
FAX: 412-338-7130
WWR# 30334241 C A Pit SJS
DISC VER Discover Open Road Card
Account number ending in 6066
Open Dote:Feb 26,2014-Close Date:Mar 25,2014
Cardmember Since 2005
Page 1 of 4
ACCOUNT SUMMARY PAYMENT INFORMATION
Previous Balance $13,589.83 `I New Balance $13,835.05
Payments and Credits — $0.00 € Minimum Payment Due' $2,084.00
Purchases + $0.00
Payment Due Date April 20,2014
Balance Transfers + $0.00
Cash Advances +
I `Includes past due amount of: $1807.00
$0.00
Fees Charged + $35.00 late Payment Warning: If we do not receive your minimum payment by the
Interest Charged + $210.22 ! date listed above,you may have to pay a late fee of up to$35.00 and your
New Balance $13,835.05
purchase and balance transfer APRs for new transactions may be increased up to
i the Penalty APR of 19.99%variable.
See Interest Charge Calculation section following the Minimum Payment Warning: If you make only the minimum payment each
Transactions section for detailed APR information period,you will pay more in interest and it will take you longer to pay off your
Credit Line $12,100 balance.For example:
I Credit Line Available $0 ! lf +l7 raoket? rlthan ?cht3rg 'o4walloyaf{fhe Attdyauwilland>3p
Cosh Advance Credit Line $6,100 tht t4rrdP,-an achtrror balancesfoWno066 poyrng inestimtak iicaitil
slatemeflf io about" �,.. I
Cash Advance Credit Line Available $0 ! Onlythe minimum amens 44 ears $84,496
. You may be able to ovoid interest on Purchases. If you would like information about credit counseling services,call 1-800-347-1121
See reverse for details.
� --- —�� REWARDS
(' __........__._.........__....._.__........_._..........._._.....__......-- —....-----............_.......__._......_A _.................
Cashback BonusO nniversory on
5 December
Opening Balance $ 0.00
1 New Coshback Bonus This Period + $ 0.00
Your FICO Credit Score on 3/19/14. Redeemed This Period —$ 0.00
t More at Discover.com/FICO !
Cashback Bonus Balance $ 0.00
Please make check payable to Discover. You are overlimit. To learn more,log in at Discover.com
Pay the sum of the Minimum Payment Due plus the remaining
overlimit amount of$1735.05.
Make Check payable to Discover NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Please fold on the perforation below,detach and return with your payment
Cl�IT1@h C UpOn 0 Pay 0"One � Pay,by Ph..ontAcco t un number ending in 6066
r
3'l�ase tltt not fall r�tp br atzrple f�'i�over,etsm 1 x(30,347`283
Minimum Payment Due $2,084.00
New Balance $13,835.05
Payment Due Dote April 20,2014
JANINE M FOOSE
. .......................
317 JUNIPER ST r£ Amount enclosed i$
CARLISLE PA 17013-2525 - _.......__._..—............._._......-.......__.._......---
PO BOX 71084
CHARLOTTE NC 28272-1084
303342Ar�t Internet payments mull be received by 5Piv1 ET to be credited as of the same day h' !1IIIIh; II! i
Address,e-mail or telephone changed?Note changes on reverse side
000001986458834280196138350500100000208400 1191NX3
JANINE M FOOSE Account number ending in 6066 Open Date: Feb 26,2014-Close Date:Mar 25,2014 Page 2 of 4
Important Information You must ensure that sufficient funds are available in your bank account,and
See your Cardmember Agreement.Your Cardmember Ag reement all transactions must comply with U.S. low.
contains all the terms of your Account.
You can set automatic payments for: (i)statement New Balance,(ii)statement
Lost or stolen cards.Report immediately! Call 1-800-347-2683. 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 on 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,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 Cardmember Agreement.If your scheduled
rights. Please see your Cardmember Agreement or visit payment is greater than the New Balance on your billing statement,that
https://discover.com/billingHghis 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 any time. 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 after affixing postage.Payments sent without proper following blanks below and retain the authorization for your records.
postage will be returned to the sender.Do not send cash. If you pay by Amount: Full Pa Min Pa L!Min Pa
check,you authorize us to use information on yyour check to make on y y y+ $
electronic fund transfer from your account at tF�e financial institution indicated U Other Amount$ ; Bank Routing#:
on your check or to process the payment as a check transaction.If a payment Bonk Account#
is processed as an electronic fund transfer,the transfer will be for the amount
of the check.When we use information from your check to make an y
Monihl on the Payment Due Date C Close Date
electronic fund transfer,funds may be withdrawn from your account as soon
as the same day we receive your payment,and you will not receive your Q Day of month(insert date)
check back from your financial institution.
The processing of your payment may be delayed if you send cash,corres- Credit Reporting.We may report information about your Account to credit
pondence or other items with your payments,if you send the payment to any bureaus.Late payments,missed payments,or other defaults on your Account
other address,or if you use an envelope other than the one provided. may be reflected in your credit report.We normally report the status and
Payments received in proper form at our processing facility by 5PM local time payment history of your Account to credit reporting agencies each month.If
on any day will be credited to your Account as of that day. Payments received you believe that our report is inaccurate or incomplete,please write us at this
of our processing facility offer 5PM local time will be credited to your Account address:Discover,PO Box 15316,Wilmington,DE 19850-5316.Please
as of the next day.If you have misplaced your envelope,send your payment include your name,address,home telephone number and Account number.
to Discover,PO Box 6103,Carol Stream,IL 601976103.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 on electronic debit.Payments made online or by phone will be billing period (at least 23 days for billing periods that begin in February).We
credited as of the day of receipt if made by 5 PM Eastern time. will not charge you any interest on Purchases if you pay your entire balance
by the due date each month.We will begin charging interest on Cash
You can pay your monthly Minimum Payment Due,or a greater amount that Advances and Balance Transfers as of the later of the Transaction Date or the
does not exceed your current Account balance,over the telephone or you can first day of the billing period in which the transaction 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 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 last four(4) Credit Balances. If your Account has a credit balance,the amount is shown
digits of the social security number of the primary borrower.By providing on the front of your billing statement. A credit balance is money that is owed
those numbers as your electronic signature,you will be agreeing to this to you. You may make charges against this amount if your Account is open.
authorization to allow us and your bank to deduct each payment you We will send you a refund of any remaining balance of$1.00 or more after
authorize,in the amount selected by you,from your bank account.You also 6 months,or as otherwise required by applicable law,or upon request made
authorize us to initiate debit or credit entries to your bank account,as to the address in the Contact Us section on page 3 of your billing statement.
applicable,to correct an error in the processing of such payment.You can
cancel a scheduled payment by phone at 1-800-347-2683 or by mail at Balance Transfers.Balance Transfers are offered at our discretion and
Discover,PO Box 30421,Salt Lake City,UT 84130-0421;however,we must accrue interest at the standard purchase rate uniesswe tell you otherwise.
receive notice at least three business days in advance of the scheduled Discover may monitor and/or record telephone calls between you and
payment.If your payments may vary in amount,we will tell you on each Discover representatives for quality assurance purposes.
monthly billing statement when your payment will be made and how much it
will be. The Discover@ card is issued by Discover Bonk,Member FDIC. TL23N
CHANGE OF ADDRESS
If correct on front,do not use.Please print clearly in blue or block ink,in the space provided.
Street Address Home Phone
I Work Phone I
I
I._._......- ..........._.._.......—...... ._......--........._............................ I ._....
I
City Email
i
3664241
To make changes to your address, email or telephone number, visit Discover.com
Continued on next page
DISC VER Discover Open Road Card
Account number ending in 6D66
Open Date:Feb 26,2014-Close Date:Mar 25,2014
Page 3 of 4
CONTACT US
0 Web Aft Mobile Phone (n uir, Mail Payments
Access your Manage your 1-800-DISCOVER ® Dscover Discover
account securely account anytime, (1-800-347-2683) PO Box 30943 PO Box 6103
at Discover.com anywhere at TDD 1-800-347-7449 Salt Lake City Carol Stream
m.Discover.com UT 84130 IL 60197-6103
Transactions
Trans.Date Post Date
Fees Mar 20 Mar 20 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD 35.00
Interest Charged INTEREST CHARGE ON PURCHASES $ 69.52
INTEREST CHARGE ON CASH ADVANCES 140.70
INTEREST CHARGE ON BALANCE TRANSFERS 0.00
TOTAL INTEREST FOR THIS PERIOD 210.22
2014 Totals Year-to-Date
TOTAL FEES CHARGED IN 2014 5 105.00
TOTAL INTEREST CHARGED IN 2014 5 662.53
----.._............................ -._..........__.............................__...__._............................_....--.......—.........__._............_.........__........._._.......—_...-_.........__.-....._._..........................—........._..........................__....__............_..........._-..........__..........
—._..--—..
Interest Charge Calculation
Your Annual Percentage Rate(APR)is the annual interest rate on your account.
Current Billing Period:28 days
ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO
TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE
Purchases 14.99% V $6,045.68 $69.52
Cash Advances 23.99% V $7,645.22 $140.70
V=Voriable Rate
Information For You
Your._._Bllin_g._Rights..
Keep This Document For Future Use
This notice tells you about your rights and our responsibilities under the Fair Credit Billing Act.
What To Do If 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
Salt 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.
Date:The date of the suspected error.
description of problem. If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake.
You must contact us:
Within 60 days after the error appeared on your statement.
At least 3 business days before an automated payment is scheduled if you want to stop payment on the amount you think is wrong.
You must notify us of any potential errors in writing.You may call us, but if you do we are not necessarily required to investigate any
potential errors and you may have to pay the amount in question.
What Will Ha.ppen._After_We._Receiv_e.Your___Letter
..__..._.._. ... ...
30334241
When we receive your letter,we must do two things:
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
1ANINE M FOOSEAccount number ending in 6066 Open Date: Feb 26,2014-Close Date:Mar 25,2014 Page 4 of 4
Information For You ... Continued
1.Within 30 days of receiving your letter,we must tell you in writing that we received your letter.We will also tell you if we have already
corrected the error.
2.Within 90 days of receiving your letter,we must either correct the error and notify you in writing of the correction or explain to you in
writing why we believe the bill is correct.
While we investigate whether or not there has been an error:
We cannot try to collect the amount and related interest 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.
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.
After we finish our investigation,one of two things will happen:
If we made a mistake:You will not have to pay the amount in question or any interest or other fees related to that amount.
If we do not believe there was a mistake:You will have to pay the amount in question, along with applicable interest and fees.We will
send you a statement of the amount you owe and the date payment is due.We may then report you as delinquent if you do not pay the
amount we think you owe.
If you receive our explanation but still believe your bill is wrong,you must write to us within 10 days telling us that you still refuse to pay.If
you do so,we cannot report you as delinquent without also reporting that you are questioning your bill.We must tell you in writing the
name of anyone to whom we reported you as delinquent, and we must let those organizations know when the matter has been settled
between us.
If we do not follow all of the rules above, you do not have to pay the first$50 of the amount you question even if your bill is correct.
Your Rights If You Are Dissatisfied With Your Credit Card Purchases
If you are 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 mailing 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,or if the company that sold you the goods or services owns us.)
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.
If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in_wrjting of:
Discover
PO Box 30945
Salt Lake City, UT 84130-0945
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.
For more information about how interest charges are calculated see your Cardmember Agreement or go to www.discover.com/interestcharges
Your FICO Credit Score is based on data from TronsUnion and may be different from other credit scores.Discover and other lenders may use different
inputs like a FICO"Credit Score,other credit scores and more information in credit decisions.If you prefer not to receive your FICO` Credit Score on your
statement, just call us at 1-800-347-3085. Please give us two billing cycles to process your request. To learn more,visit Discover.com/FICO.Your FICO'
score is provided for your own non-commercial personal review,use and benefit. FICO is a registered trademark of the Fair Isaac Corporation in the United
States and other countries.
30334241
VERIFICATION
Oaudik
LA6akn3,DVY+ %5641("S�-
(Name) (Tit1
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 f h & 7d
(Signature)
JANINE M FOOSE DB Servicing Corporation servicing affiliate
XXXXXXXXXXXX 6 0 6 6 For Discover Bank
WWR# 30334241 C A Pit SJS
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
c,
THE PROTHONOTARY
2014 AUG -8 AHII: 02
CUMBERLAND COUNTY
PENNSYLVANIA
5x
of CotolLtv.4,4
OFFICE OF THE SHERIFF
Discover Bank
vs.
Janine M Foose
Case Number
2014-4403
SHERIFF'S RETURN OF SERVICE
07/30/2014 09:02 PM - Deputy Dawn Kell, 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: Janine M Foose at 317 Juniper Street, Carlisle Borough, Carlisle, PA 17013.
g .
DAWN KELL, DEPUTY
SHERIFF COST: $34.78 SO ANSWERS,
August 05, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoft. Inc.
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