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Home My WebLink About14-4652 Supreme Coin fof-Pennsylvania NVWR# 30334318 C A Pit SJS CouAlfCommon Pleas '� For Prothonota Use Only: ivifCover.•She& �►' �. i .4, CUMBERLAND'Scounty, Docket No: f The inforination collected on this form is used solely for- court administration purposes. This form does not supplement or replace the filing attd service of pleadings o)-other papers as required by lair,or rules of court. Commencement of Action: S 13 Complaint ❑ Writ of Summons ❑ Petition E Transfer from Another Jurisdiction Declaration of Taking DISCOVER BANK C Lead Plaintiff's Name: Lead Defendant's Name: T JACOB R BINNER I 0 Are money damages requested? El Yes ❑ No Dollar Amount Requested: E3 within arbitration limits N (check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes Cal No Is this an MDJ Appeal? ❑ Yes 0 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] 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 10,009 9 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 ❑ Product Liability(does not include ❑ 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 ❑ 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: i Updated 1/1/2011 FILED-OFFICE Uri E PR0TH0tgQTHf�y 4 5111 AUG -6 PM 1: 32 CUM'BER AND COUNTY PENNSYLvAwA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: l �� VS . COMPLAINT IN CIVIL ACTION JACOB R BINNER 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 30334318 C A Pit SJS CID OLUA �GU� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Vs . Civil Action No JACOB R BINNER 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 630 BOSLER AVE LEMOYNE, PA 17043 5 . Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2773 . 6 . Defendant made use of said credit card and has a current balance due of $1589 . 88 . 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, JACOB R BINNER, INDIVIDUALLY, in the amount of $1589. 88 and costs . William T. f4olczaif, 47437 WELTMAN, WEINBERG & REIS CO. , L. P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 (412) 434-7955 FAX: 412-338-7130 WWR# 30334318 C A Pit SJS DISC VER Discover More Card Account number ending in 2773 Open Date:Feb 25,2014-Close Date:Mar 24,2014 Cardmember Since 2010 ACCOUNT SUMMARY PAYMENT INFORMATION Page 1 of 4 Previous Balance $1,533.72 / New Balance $1,589.88 ~ Payments and Credits — $0.00 Minimum Payment Due $566.00 Purchases + $0.00 j 1 + Payment Due Date April 19, 2014 j Balance Transfers $0.00 Cash Advances + $0.00 .Includes past due amount of: $489.00 Fees Charged + $35.00 late Payment Warning: If we do not receive your minimum payment by the Interest Charged + $21.16 date listed above,you may have to pay a late fee of up to$35.00 and your New Balance $1 589 88 purchase and balance transfer APRs for new transactions may be increased up to the Penoliy APR of 24.99%variable. j See Interest Charge Calculation section following the Transactions section for detailed APR information 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 I Credit Line $1,000 balance.For example: Credit Line Available $0 1 make nol7rJd,hanalchtlrces 1�p4yl�poya## ,e. ArrcJauwttlenclvt Cash Advance Credit Line $200 u�ingtltt ard�ttdaochrnattift bddeceaT>Cs, artthls ptaYtrag.ttnesfir l�diottil ! Yap t �_ ,s1Q3em�nt'f�ahaul,:;; cif Cash Advance Credit Line Available $0 j Only the minimum payment 4 years $2,032 You may be able to avoid interest on Purchases. j If you would like information about credit counseling services,call 1-800-347-1121. 1 See reverse for details. J --__ —� --- REWARDS — -A-nniversa AManth Cashback Bonus® December 1 526 I Opening Balance $ 0.00 j New Cashbock Bonus This Period + $ 0.00 Your FICO'Credit Score on 3/18/14. Redeemed This Period _$ 0,Q0 LMore at Discover.com/FICO 1 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$589.88. Make Check payable to Discover Please fold on the perforation below,detach and return with your payment NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Cl�/tt7@11f. o11$7ot1, phli1QDy;13)I iPQlie Account number ending in 2773 0 1}Jens r10 npr Fa7d chip n[stupl t�t3cover carim: 1 x(10 3ai7 2:;183 Minimum Payment Due $566.00 Ijl"'lll'Ili'IL1�11'�I�II'II�'i11��1"Illlll�l�llj l�llll 111 New Balance $1,589.88 Payment Due Date April 19,2014 JACOBR GINNER ..........................___........................................................................................................................................... 630 BOSLER AVE Amount enclosed $ LEMOYNEPA 1 7043-1 81 6 ........_.................................__............-----........... .._........ —--................ PO BOX 71084 CHARLOTTE NC 28272-1084 303343-M Internet payments must be received by 5PM ET to be credited as of the some day '11:11 111 ;I 1111i11111111111111:ljlll til � U I Ijliilillllil�l Address,e-mail or telephone changed?Note changes on reverse side 000001986456919605667015898800292000056600 EVA TUT I81T ,... JACOB R BINNER _ Account number ending in 2773 Open Date_Feb 25,2014-Close Date:Mar 24,2014 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 Agreement oil transactions must comply with U.S. law. contains all the terms of your Account. You can set automatic payments for: (i)statement New Balance,(ii)statement Lost or stolen cards.Report immediatelyl 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 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 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/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 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 ❑Full Pa check,you authorize us to use information on your check to make an Amount: y [I Min Pay L Min Pay+ S electronic fund transfer from your account at the financial institution indicated D Other Amount$ Bank Routing#: on your check or torocess the payment as a check transaction.If a payment is processed as on electronic fund transfer,the transfer will be for the amount Bank Account# 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 Monthly on the❑Payment Due Date U Close Date as the some day we receive your payment,and you will not receive your Q Day of month(insert dale) check back from your financial institution. The processing of your payment may be delayed if you send cosh,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 at our processing facility after 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 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 atleast 25 days after the close of each resubmit it as an 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, Rote. 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 Rafe. 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 io 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 51.00 or more after authorize,in the amount selected by you,from your bank account.You also 6 months,or as otherwise required by applicable low,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 unless we 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 Bank,Member FDIC. TL23N CHANGE OF ADDRESS 1 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 i ....._.............--.......-_.............._.........--............_............_...............-........_—......._—...........................-.................._...., ...-........-_..........._..........................._._..........__.......__.............-................._....._.._.............._.... ......—._ City Email I 361647ii18 To make changes to your address, email or telephone number, visit Discover.com Continued on next page DISC VER Discover More Card Account number ending in 2773 Open Date:Feb 25,2014-Close Date:Mar 24,2014 Page 3 of 4 CONTACT US 1 0 Web A9k Mobile Phone Inquiry Mail Payments Access your Manage your 1-800-DISCOVER Discover ® Discover I 0 0 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 Scream m.Discover.com UT 84130 IL 60197-6103_ ; Transactions Trans.Date Post Date Fees Mar 19 Mar 19 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD 35.00 Interest Charged INTEREST CHARGE ON PURCHASES $ 20.18 INTEREST CHARGE ON CASH ADVANCES 0.98 INTEREST CHARGE ON BALANCE TRANSFERS 0.00 TOTAL INTEREST FOR THIS PERIOD 21,16 2014 Totals Year-to-Date TOTAL FEES CHARGED IN 2014 $ 105.00 TOTAL INTEREST CHARGED IN 2014 $ 65.10 .....---.._....__...._---..__........---................._.....—_._......... ._..........._._...—_....__......__.._............._........._......_...._..._......__............._............_...._...--.......__....._........................_...._............--......._.........._........._....._......._.........._..._....._...._...........__.........__........_._... 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 19.99% V $1,315.79 $20.18 Cash Advances 23.99% V $53.10 $0.98 V=Variable Rate Information For You Your Blli_n.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_Happen._After._We._Receive.Your,..Letter 30$3431$ When we receive your letter,we must do two things: NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION JACOB R BINNER Account number ending in 2.773 Open Date:Feb 25,2014-Close Dote:Mar 24,2014 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 ore 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,Writing at: Discover PO Box 30945 Salt Lake City, LIT 84130.0945 While we investigate,the some 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/interesicharges Your FICO Credit Score is based on data from TransUnion 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. 30334318 DISC VER Discover More Card Account number ending in 2773 Open Date:Feb 25,2014-Close Date:Mar 24,2014 Cordmember Since 2010 Page 1 of 4 ACCOUNT SUMMARY PAYMENT INFORMATION rPrevious Balance } $1,633.72 New Balance $1,589.88 Payments and Credits — $0.00 ! j Minimum Payment Due $566.00 Purchases + $0.00 i Balance Transfers + $0.00 Payment Due Date April 19,2014 } `Includes past due amount of: $489.00 Cash Advances $0.00 i 1 Fees Charged + $35.00 I Late Payment Warning: If we do not receive your minimum payment by the Interest Charged + $21.16 date listed above,you may have to pay a late fee of up to$35.00 and your + New Balance $1,589.88 ? purchase and balance transfer APRs for new transactions may be increased up to i the Penalty APR of 24.99%variable. i See Interest Charge Calculation section following the Minimum Payment Warning: If you make only the minimum payment each Transactions section for detailed APR information . . _ _ I period,you will pay more in interest and it will take you longer to pay off your Credit Line $1,000 balance.For example: I Credit Line Available $0 € �fycsp okelta2rdd�tirmo�lthdrg% ;Yp[t�+ lmygffhe. AndyopW, *4md.>tp Cash Advance Credit Line $200 srs�tag ftcard and uelttrrontb 6alar�ce slio�vnOn,thir pcying'. st esfimt3lelifotal. I .1 slaternenfie abaul.:,..., a{ Cash Advance Credit Line Available $0 Onlythe minimum payment 1 4 ears $2,032 I You may be able to avoid interest on Purchases. If you would like information about credit counseling services,call 1-800-347-112 See reverse for details. / -- -- --------� REWARDS Cashback BonusO Anniversary Month l December 526 Opening Balance S 0.00 Your FICO Credit Score on 3/16/14. New Cashbock Bonus This Period + $ 0.00 j t Redeemed This Period More at Discover.com/FICO —$ 0.00 I 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 overlimii amount of$589.88. Make Check payable to Discover NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Please fold on the perforation below,detach and return with your payment Ll►1Ti@n alJpbn 0 Poi/onli.0 � PCj►by Phond. Account number ending in 2773 Pleased near fold clip or stzrPle. [ i3teverar 1 ()37 2583 Minimum Payment Due $566.00 lI"'IIIlI1i'!lil�ll'�I�II'Ili'il'��1i1I!Illli��lilllllilll New Balance $1,589.88 Payment Due Date April 19,2014 JACOBR BfNNER ..........................................................................................._.................................... 630 BOSLER AVE s Amount enclosed 5 LEMOYNEPA 17043-1816 .......................................__.....................__..........................__..........--......._..................... PO BOX 71084 CHARLOTTE NC 28272-1084 �1jI III I11 VIII 1111:M:1 111 1'I 11111 hI 1 11111111111 30334alLb Internet payments must be received by 5PM ET to be credited as of the some day Address,e-mail or telephone changed?Note changes on reverse side 00000198645691960566?015898800292000D56600 JACOB R BINNER _ Account number ending in 2773 Open Date:Feb 25,2014-Close Dote:Mar 24,2014 Page 2 of 4 .......... Important Information You must ensure that sufficient funds are available in your bank account,and See your Cardmember Agreement.Your Card member Agreement all ironsadions 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,Soli 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 Cordmember 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/billingHghts for o 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 port 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 onlyxour paymentand the bottom portion of this statement If you enroll by phone in our automatic payment service,please fill-in the 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 check,you authorize us to use information on your check to make an Amount: 0 Full Pay []Min Pay 01 Min Pay+ $ electronic fund transfer from your account at the financial institution indicated D Other Amount$ Bank Routing#: on your check or toprocess the payment as a check transaction.If a payment is processed as on electronic fund transfer,the transfer will be for the amount Bank Account# 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 Monthly on the 11 Payment Due Date !1!Close Date as the some day we receive Your payment,and you will not receive your [] Day of month(insert dale) 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 of 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 at our processing facility after 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 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 (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 con 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 con 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 of 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 Dote 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 Rafe. 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 Iasi 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 low,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 on error in the processing of such payment.You can cancel a scheduled payment by phone at 1-800-347-2683 or by mai!at Balance Transfers.Balance Transfers are offer d at our discretion and Discover,PO Box 30421,Salt Lake City,UT 84130-0421;however,we must accrue interest of 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 tolls 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 Bank,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 Work Phone City I Email ! 36US18 To make changes to your address, email or telephone number, visit Discover.com Continued on next page DISC VER Discover More Cala Account number ending in 2773 Open Date:Feb 25,2014-Close Date:Mar 24,2014 Page 3 of 4 CONTACT US _ ..__ __--------_ . ............... ..--..._. _............._.............__.........--.................._.............. - _......_._ ..-_.........-- 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 1 at Discover.com anywhere at TDD 1-800-347-7449 Salt Lake City Carol Stream 1_ m.Discover.com UT 84130 IL 60197-6103 Transactions Trans.Date Post Date Fees Mar 19 Mar 19 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD 35.00 Interest Charged INTEREST CHARGE ON PURCHASES $ 20.18 INTEREST CHARGE ON CASH ADVANCES 0.98 INTEREST CHARGE ON BALANCE TRANSFERS 0.00 TOTAL INTEREST FOR THIS PERIOD 21.16 2014 Totals Year-to-Date TOTAL FEES CHARGED IN 2014 $ 105.00 TOTAL INTEREST CHARGED IN 2014 S 65.10 ........._........._.-..........—---...............-----..........._._......__.............-._..........._.....---.........-_........----.........__.........__.............. ..............__.._....---........--.........._......—........--..........._....__....._.............._......_..-...........-----............._.............-._......---......__.._........--- 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 19.99% V $1,315.79 $20.18 Cash Advances 23.99% V $53.10 $0.98 V=Variable Rate Information For You Your B Billing l i ngR Rights: s_: .._ --- 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 ......-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. DoIJ_ar 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 Happen We Receive Your ._.._... .._. 303 4$1� When we receive your letter,we must do two things: NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION JACOB R BINNER Account number ending in 2773 Open Date:Feb 25,2014-Close Date:Mar 24,2014 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 fried 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-writing 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 goiowww.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`k' score is provided for your own non-commercial personal review,use and benefit. FICO is a registered trademark of the Fair Isoac Corporation in the United States and other countries. 30334318 VERIFICATION an (Name) (Titl 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 —...6 (Signature) JACOB R BINNER DB Servicing Corporation servicing affiliate XXXXXXXXXXXX2 7 73 For Discover Bank WWR# 30334318 C A Pit SJS Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ r!LED-OF F ICF nn w of Cumforti,t,,. I 6 HE pROT hONO itii'; OFFICE OF Tit;: SHERIFF 22.014 AUG ILI Pik 3: 06 CU PE NNSYLVAN A COUNTY Discover Bank vs. Jacob R Binner Case Number 2014-4652 SHERIFF'S RETURN OF SERVICE 08/11/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jacob R Binner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 630 Bosler Avenue, Lemoyne Borough, Lemoyne, PA 17043. Deputies were advised by the defendant's grandmother that the defendant does not reside at this address but is believed to be residing in Hummelstown. SHERIFF COST: $51.08 SO ANSWERS, August 12, 2014 (c; CountySuito Sheriff, Tel oft, h,c. RONNR ANDERSON, SHERIFF WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T Molczan, Esquire I.D. No.47437 436 Seventh Avenue, Suite 2500 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 30334318 I -ITE PRO THONO Attorney for Pl.T),...6 PM 2: 514 CUMBERLAND COUNTY PENNSYLVANIA DISCOVER BANK Plaintiff vs. JACOB R BINNER Defendant(s) Cumberland County Court of Common Pleas NO. 14 4652 CIVIL PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By William T Molczan,/squire Attorney for Plain Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Di Lilira•i1'`a� tr 1 �}- ?ROI I t 7.0t4 E43 \1 -3 PIA 3: 55 CU 1,041 SYLVAt4IRTY • PCW' OFF ICE OFTHE S SF,iFF Discover Bank vs. Jacob R Binner Case Number 2014-4652 SHERIFF'S RETURN OF SERVICE 10/24/2014 06:16 PM - Deputy Jamie DiMartile, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Tracey Binner, Mother, who accepted as "Adult Person in Charge" for Jacob R Binner at 630 Bosler Avenue, Lemoyne Borough, Lemoyne, PA 17043. IE DIMARTILE, DEPUTY SHERIFF COST: $46.08 SO ANSWERS, October 27, 2014 c) CountySuite Sheriff. Te!eoseff, Inc. RONN' R ANDERSON, SHERIFF WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No. 47437 436 7th Ave Ste 2500 Pittsburgh, PA 15219 Phone: (412) 434-7955 Fax: (412) 338-7130 File # 30334318 WTM/SJS Attorney for Plaintiffs DISCOVER BANK vs. JACOB R BINNER CUMBERLAND County Court of Common Pleas No.: 14 4652 CIVIL PRAECIPE TO DISMISS WITH PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above matter with prejudice WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan, Es Attorney for Plaintiff 1111111111111111 IIII 111111111111111111111 IIIII 11111 11111 IIII IIII