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HomeMy WebLinkAbout14-5760 Supreme CouttWOUXennsylvania coinr,�sou.co`�lmag'�Pleas For Prothonotary Use Only: CIV,it e Shdet Docket No: 1 S CUMBERLANb County4.11, I -5760 Oivlf I6m The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required bylaw or rules of court. Commencement of Action: S K Complaint 1 Writ of Summons 0Petition C Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: DISCOVER BANK TANIA CRISANTI T Dollar Amount Requested: Qwithin arbitration limits I Are money damages requested? El Yes 1=1 No check one)) Qoutside arbitration limits O N Is this a Class Action Suit? 0 Yes S No Is this an MDJAppeal? ❑ Yes F1 No A Name of Plaintiff/Appellant's Attorney: AMY F DOYLE, ESQUIRE 'J 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 ❑I Intentional IJ Buyer Plaintiff Administrative Agencies Malicious Prosecution x] Debt Collection:Credit Card ❑ Board of Assessment 0 Motor Vehicle CI Debt Collection:Other C Board of Elections Nuisance Dept.of Transportation Q Premises Liability CI Statutory Appeal:Other S Q Product Liability (does not include tort) � Employment Dispute: mass E Discrimination Slander/Libel/Defamation C Q Other: Employment Dispute:Other JI Zoning Board T ❑I Other: I ❑ Other: O MASS TORT IJ Asbestos N Q Tobacco IJ Toxic Tort-DES 0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS F-1 Toxic Waste ❑ Ejectment Q Common Law/Statutory Arbitration B ❑ Other: 1 Eminent Domain/Condemnation 1-5 Declaratory Judgment iJ Ground Rent Mandamus CI Landlord/Tenant Dispute Non-Domestic Relations [J Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY rl Mortgage Foreclosure:Commercial Quo Warranto U Dental Q Partition Replevin El Legal ] Quiet Title -1 Other: Medical J Other: E] Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK NO. 14- 5700 �ivi l`�erm 2500 LAKE PARK BOULEVARD WEST VALLEY UT 84120 PLAINTIFF VS. - - TANIA CRISANTI i } r 14 RIVERVIEW DR -_- ENOLA PA 17025 DEFENDANT(S) NOTICE TO DEFEND ' // ry 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 is served, by entering a written appearance, personally of by 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. Cumberland Cty Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800/990-9108 O *IIS.115 Po ATT-Y C� 11851 3f17/S FILE NO. 10008587 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK NO. 2500 LAKE PARK BOULEVARD WEST VALLEY UT 84120 PLAINTIFF vs. TANIA CRISANTI 14 RIVERVIEW DR ENOLA PA 17025 DEFENDANT(S) NOTICIA USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas,usted tienen que tomar accion dentro veinte(20)dias despuds que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o objeciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un j uzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland Cty Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800/990-9108 FILE NO. 10008587 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK NO. 2500 LAKE PARK BOULEVARD WEST VALLEY UT 84120 PLAINTIFF VS. TANIA CRISANTI 14 RIVERVIEW DR ENOLA PA 17025 DEFENDANT(S) COMPLAINT Plaintiff, DISCOVER BANK, by its attorneys, Jaffe&Asher LLP, for its complaint herein against Defendant, TANIA CRISANTI ("Defendant"), alleges as follows: L Plaintiff, Discover Bank, is a bank organized and existing under the laws of the State of Delaware with a place of business located at 1500 Lake Park Boulevard, West Valley, UT 84120. 2. The Defendant, TANIA CRISANTI, is an adult individual, residing at 14 RIVERVIEW DR, ENOLA PA 17025, CUMBERLAND County. Count 1 - Breach of Contract 3. The Defendant heretofore entered into a written loan agreement with the Plaintiff(the "Loan Agreement"). 4. Defendant has defaulted in payment on the loan and has refused to pay in breach of the Loan Agreement and despite due demand and full compliance by Plaintiff with the Loan Agreement. A true and correct copy of the most recent statement evidencing the balance due at the time the last statement was issued was mailed to the Defendant and is attached hereto, incorporated herein, and marked as Exhibit "A". 5. Subsequent to the issuance of the last statement which was mailed to Defendant, financial activity/adjustments may have occurred with respect to the loan balance. A true and correct copy of the ledger showing the current balance due in the amount of$6,642.00 on the loan which includes all activity/adjustments, if any, is attached hereto, incorporated herein, and marked as Exhibit "B". 6. By reason of the foregoing, Plaintiff is entitled to judgment against Defendant for breach of contract in the sum of$6,642.00, in addition to any court costs. FILE NO. 10008587 WHEREFORE, Discover Bank demands judgment against Defendant on Count 1 in the sum of$6,642.00, plus costs. Respectfully submitted, Amy F. Doy e Es ire, ID #87062 Philip Warholic, Esquire, ID #86341 JAFFE &ASHER, LLP 11 East Market St., Suite 102 York, PA 17401 717-885-0718 877-202-9420 717-885-0726 (facsimile) Counsel for Plaintiff FILE NO. 10008587 ATTORNEY: ACCOUNT NUMBER: XXXXXXXX1188 PRINCIPAL BALANCE: $6,155.92 INTEREST DUE: $291.08 FEES: $195.00 TOTAL BALANCE DUE: $6,642.00 Account Holder(S): TANIA CRISANTI STATE OF UTAH COUNTY OF SALT LAKE Robert Lape personally appeared before me on this day and after being duly sworn,according to law, and upon my oath and states as follows: I am a Litigation Support Specialist for DB SERVICING CORPORATION,the wholly owned servicing affiliate of DISCOVER BANK,an FDIC insured Delaware State Bank. DB SERVICING CORPORATION is responsible for,among other things,maintaining account records pertaining to Discover Personal Loan accounts and interacting with Discover Personal Loan account holders with regard to payments owed on those accounts. THAT this affidavit is made on the basis of my personal knowledge and in support of the Plaintiffs suit on account against the Account Holder(s). THAT,in my capacity as Litigation Support Specialist,I have knowledge regarding,and access to,records regarding the above referenced Discover Personal Loan account,identified by Account Number(hereinafter, "Account"),and above referenced Account Holder(s). DB SERVICING CORPORATION maintains these records in the ordinary course of its business,and the records are updated with information on events(such as the initial funding of the loan and payments on the Account)by individuals with personal knowledge of those events or by automated processes that track such events at or near the time that the events occur. The same systems that record this information also generate periodic statements that are sent to account holders,such as Account Holder(s),and store copies'of these periodic statements. In addition,these same record-keeping systems contain information about which version of Discover Bank's terms and conditions has been communicated to an account holder and accepted by an account holder at the time of the funding of the loan. I have personally inspected the records pertaining to the Account of the Account Holder(s),including the last periodic statement sent to the Account Holder(s)by DB SERVICING CORPORATION, the applicable terms and conditions,the balance due on the Account and whether the Account Holder(s)have made payments on that balance. THAT the Account is in default because the Account Holder(s)have not paid the amounts due and owing to Discover Bank on the Account. THAT the business records maintained by DB SERVICING CORPORATION and described above show that the Account Holder(s)' Account with Discover Batik is governed by terms and conditions referred to by Discover Bank and DB SERVICING CORPORATION as the Loan Agreement.A true and correct copy of these terms and conditions has been provided to DB SERVICING CORPORATION's counsel in this case. THAT Exhibit A is a true and accurate copy of the most recent statement sent by DB SERVICING . CORPORATION to the Account Holder(s),retrieved from the record-keeping system described above. THAT Exhibit B is a true and accurate copy of information retrieved from DB SERVICING CORPORATION's record-keeping system that shows the current balance due and owing on the Account Holder(s)' Account. The balance shown on Exhibit B differs from the balance shown on the last statement attached as Exhibit A because Exhibit B reflects activity that occurred with respect to the Account after the last statement was created. That as of the signing of this affidavit,the true and correct amount due and owing on the Account is$6,642.00. DB SERVICING CORPORATION has access to a system of records maintained by the United States Department of Defense,which allows DB SERVICING CORPORATION to ascertain whether a particular person is engaged in active duty in any branch of the U.S.military. It is the regular practice of DB SERVICING CORPORATION to query this system with respect to any account holder prior to initiating a collection action against that account holder,and DB SERVICING CORPORATION maintains records in the normal course of its business that indicate the results of that query. Based on my review of the account records applicable to Debtor(s),to the best of my knowledge and belief the above referenced Account Holder(s)is not engaged in any of the military services of the United States. Further,according to the records maintained by DB SERVICING CORPORATION,which include the address associated to which account statements are sent to a cardholder,the Account Holder(s)is a resident of the State and of the County in which this action has been filed. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Robert Lape SUBSCRIBED TO AND SWORN TO before me this 28th day of gl, 14. Notary CRYSTAL AHLEMANN Notary Public,State of Utah " Commission#604813 My Commission Expires January 19,2015 ENC: Last Statement, Loan History EXHIBIT"A" DISCOVER Monthly Statement FINANCIAL SERVICES Personal Loan Account t11•• Statement Date Ending Loan Balance 1188 8/20/10 9,488.72 FPost Date Effective Date Transaction Description Amount 08 05 08 05 REG PMT-EFF DTE 194.46 PAYMENT SUMMARY Amount Past Due Other Charges Due Scheduled Monthly Payment Total Amount Due if Received by the Payment Due Date of 9/09110 .00 .00 T194.46 194.46 Total Amount Due if Received After the Payment Due Date of 9/09/10 233.46 IMPORTANT MESSAGES Discover Credit Protection... because life doesn't come with guarantees! Protect your Discover Personal Loan account with Credit Protection and put your monthly payments on hold for up to 1 or 2 years when the unexpected happens. Call to ask your Account Manager about Credit Protection todayl Peace of mind may cost less than you think. Please Note: If you're already enrolled in DirectPay (and received enrollment confirmation), this statement is for your Information only and you do not need to make a separate payment. For Customer Service Call 40 1-877-256-2632 For TDD(Telecommunication Device for the Deaf)call 4 1-866-710-3357 If you pay the ENDING PRINCIPAL BALANCE shown on this statement,you will have a balance due of finance charges accrued from the date of your last payment to the dale we receive your payment•plus any unpaid additional fees and/or finance charges that may have been added but not yet paid. RETAIN THIS PORTION FOR YOUR RECORDS-SEE REVERSE SIDE FOR IMPORTANT INFORMATION T PLEASE DETACH ON PERFORATION AND RETURN BOTTOM PORTION WITH YOUR PAYMENT T DISCOVER Account Numhe.- Please Write Amount Paid 1 1188 -* FINANCIAL SERVICES Total.mous Due if Recieved by the Payment Due Date of 9109110 PO BOX 30954 194.46 Salt Lake City,UT 84130-0954 Total Amount Due if Received after the payment Due Date of 9109/10 Please make checks payable to: 233.46 Discover Personal Loans 0 Please print change of address and phone correction above and put an'X in box. ' TANIA M CRISANTI DISCOVER PERSONAL LOANS 25 CURRY HOLLOW RD P.O.BOX 6105 PITTSBURGH PA 15236 CAROL STREAM,IL 60197-6105 �— ~,1889100019446100000000 MAILING ADDRESSES PAYMENTS PAYMENTS CUSTOMER SERVICE Overnight Delivery: Correspondence: Discover Personal Loans Discover Personal Loans Discover Personal Loans P.O.Box 6105 2100 W Corporate Dr-Suite A P.O.Box 30954 Carol Stream,IL 60197-6105 Addison,IL 60101-1446 Salt Lake City,UT 84130-0954 (DO NOT SEND PAYMENT) IMPORTANT INFORMATION See your Loan Agreement: Your Loan Agreement and Truth-in-Lending Disclosure contain all the terms of your Account. Payments: Send only your payment,the bottom portion of this statement and any completed response forms for additional Discover Financial Services product offers in the envelope provided.Do not send cash.By sending your check,you authorize us to use information on your check to make an electronic fund transfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. If payment 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 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 check back from your financial institution. The processing of your payment may be delayed if you send cash,correspondence or other items with your payment,if you send the payment to any other address or if you use an envelope other than the one provided.Payments received by 1 PM local time at the payment address on any Monday through Friday that is not a bank holiday will be credited as of the date of receipt.Payments received after the time specified will be credited as of the next day which is not a weekend or bank holiday. If you have misplaced your envelope,send your payment to the payment mailing address listed above.Please allow 7-10 days for delivery. If your payment is returned unpaid,we reserve the right to resubmit it as an electronic debit. You can pay your scheduled monthly payment or a greater amount that does not exceed your remaining current loan balance over the telephone or you can setup automatic payments through a customer service representative by calling 877-256-2632. You may also select a desired payment date that occurs before your next payment due date.You will need this statement and your bank account information.You must ensure that sufficient funds are available in your bank account,and all transactions must comply with U.S.law. You will be asked to provide the first 5 digits of your account statement zip code. By entering those numbers as your electronic signature,you will be agreeing to this authorization to allow us and your bank to deduct each payment you authorize,in the amount selected by you,from your bank account,and to initiate debit or credit entries to your bank account,as applicable,to correct an error in the processing of such payment. You can cancel a scheduled payment;however we must receive notice at least three business days in advance of the scheduled payment.You may notify us by phone at 877-256-2632 or by mail at the correspondence address listed above.If your scheduled payment date falls on a weekend or bank holiday,your payment will be processed the business day prior to the weekend or bank holiday. If your scheduled payment is not enough to cover the Total Amount Due as listed on your monthly billing statement,you will be responsible for paying the difference. If the scheduled payment is greater than the Total Amount Due,any excess will be applied in accordance with your Loan Agreement. Credit Reporting. We may report information about your account to credit bureaus.Late payments, missed payments,or other defaults on your account may be reflected in your credit report.If you believe that our report is incorrect or incomplete, please write us at the correspondence mailing address listed above.Please include your name,address, home telephone number and Account number. CUSTOMER SERVICE For Customer Service Information,call 877-256-2632. For TDD(Telecommunication Device for the Deaf)calls,please dial: 1-866-710-3357. PAYMENT REMINDERS 1.Please write your account number on your check. 2.Please indicate the amount of your payment in the designed box on the coupon. 3.Please make check payable to:Discover Personal Loans. 4.Please make sure your check and coupon are both included in the enclosed return envelope. 5.Please do not include any other Discover Financial Services product payments. Discover Personal Loans are made by Discover Bank,member FDIC. EXHIBIT`B" DISCOVER BANK PAGE 0001 CONSUMER/INSTALLMENT LOAN NOTE NBR t 1_188-000 REASON- REQUESTED , SHORT NAME CRi5juvi TANIA PROC-THRU 4-24-2014 *------------BALANCE DATA-------------* TANIA M CRISANTI NOTE AMOUNT* 10,500.00 25 CURRY HOLLOW RD PRINCIPAL BALANCE .00 PITTSBURGH PA 15236 IAT BALANCE 291.08 PAYOFF AMOUNT AS OF 4-23-14 6,642.00 PERCENTAGE SOLD OOOOOOOOOt CONTACT- -------------INTEREST DATA------------* TITLE- INTEREST RATE .0000 HOME PHONE DAILY INT_ FACTOR .000000 BUS PHONE INTEREST PAID YTD 6.74 OFFICER TLP, DEALIIK uuuuu GUARANTEE CODE 2 ACC/YR BASE ACT-365/366 *-------------CREDIT DATA--------------* PAST DUE Cl 1 PAST DUE 30 DYS 1 x---------------DATES-----------------* PAST DUE C2 1 PAST DUE 60 DYS 1 NOTE DATE 11-09-09 PAST DUE C3 0 PAST DUE 90 DYS 1 LAST RENEWED 00-00-00 TOTAL PAST DUE _00 NEXT MATURITY 11-09-15 OLDEST PMT DUE DATE 00-00-00 LAST ACTIVE 03-Z4-14 LOAN FEES DUE 195.00 INTEREST PAID-TO 10-07-12 LATE FEES DUE .00 LAST PRINCIPAL REDUCTION 03-29-13 CLASSIFIED/RISK / *---------------------------EXTENSION/RENEWAL COUNTERS-------------------------* TO-DATE MTD YTD LAST TRAM DATE NBA OF EXTENSIONS 00-00-00 NBR OF SKIP PAYMENTS 00-00-00 NBA OF DEFERMENTS 00-00-00 NBP. OF RENEWALS 00-00-00 NBR OF WORKOUT RENEWALS 00-00-00 NBR OF DUE DATE CHANGES 00-00-00 *----------------------------------- HISTORY------------------------------------* POST DTH EFF DATE TCI TRANS DESCRIPTION AMOUNT TYPE NEW BALANCE DUB DATE PAID-TO TC2 I-RATE FSA 10500.00 11-09-09 11-09-09 033 1ST DISBURSE 10500.00 PRINCIPAL 00-00-00 11-09-09 00 9.9900 10360.14 I 11-30-09 11-28-09 083 REG PMT-EFF DTE 139.86 PRINCIPAL 12-09-09 11-28-09 02 9.9900 . 54.60 INTEREST 11-30-09 DPL MAIL BANCTEC ADDISON 10284.78 01-11-10 01-09-10 083 REG PMT-EFF DTH 75.36 PRINCIPAL 01-09-10 01-09-10 02 9.9900 119.10 INTEREST 01-11-10 DPL MAIL BANCTEC ADDISON 10169.13 02-08-10 02-06-10 083 REG PMT-EFF DTE 115.65 PRINCIPAL 02-09-10 02-06-10 02 9.9900 78.81 INTEREST 02-08-10 DPL MAIL BANCTEC ADDISON DISCOVER BANK PAGE 0002 CONSUHER/INSTALLMENT LOAN NOTE NBR ;�8-000 REASON- REQUESTED SHORT NAM1 :ANIA PROC-THRU 4-24-2014 *------------------------- ----------HISTORY------------------------------------x POST DTE EFF DATE TCI TRANS DESCRIPTION AMOUNT TYPE NEW BALANCE DUE DATE PAID-TO TC2 I-RATE PSA 10047.04 03-04-10 03-04-10 083 REG PMT-EFF DTE 122.09 PRINCIPAL 03-09-10 03-04-10 02 9.9900 72.37 INTEREST 03-04-10 DPL MAIL BANCTEC ADDISON 9937.83 04-05-10 04-04-10 083 REG PMT-EFF DTE 109.21 PRINCIPAL 04-09-10 04-04-10 02 9.9900 85.25 INTEREST 04-05-10 DPL MAIL BANCTEC ADDISON 9824.96 05-04-10 05-04-10 083 REG PHT-EFF DTE 112.87 PRINCIPAL 05-09-10 05-04-10 02 9.9900 81.59 INTEREST 05-04-10 DPL MAIL BANCTEC ADDISON 9716.55 06-07-10 06-05-10 083 REG PMT-EFF DTE 108.41 PRINCIPAL 06-09-10 06-05-10 02 9.9900 86.05 INTEREST 06-07-10 DPL MAIL BANCTEC ADDISON 9593.90 07-02-10 07-02-10 083 REG PMT-EFF DTE 122.65 PRINCIPAL 07-09-10 07-02-10 02 9.9900 71.81 INTEREST 07-02-10 DPL HAIL BANCTEC ADDISON 9488.72 08-05-10 08-05-10 083 REG PMT-EFF DTH 105.18 PRINCIPAL 08-09-10 08-05-10 02 9.9900 89.28 INTEREST 08-05-10 DPL MAIL BANCTEC ADDISON 9377.36 09-07-10 09-06-10 083 REG PMT-EFF DTE 111.36 PRINCIPAL 09-09-10 09-06-10 02 9.9900 83.10 INTEREST 09-07-10 DPL MAIL BANCTEC ADDISON 9265.03 10-08-10 10-08-10 083 REG PMT-EFF DTE 112.33 PRINCIPAL 10-09-10 10-08-10 02 9.9900 82.13 INTEREST 10-08-10 DPL MAIL BANCTEC ADDISON 9139.04 11-04-10 11-04-10 083 REG PHT-EFF DTE 125.99 PRINCIPAL 11-09-10 11-04-10 02 9.9900 68.47 INTHRHST 11-04-10 DPL MAIL BANCTEC ADDISON 9034.63 12-10-10 12-10-10 083 REG PHT-EFF DTH 104.41 PRINCIPAL 12-09-10 12-10-10 02 9.9900 90.05 INTEREST 12-10-10 DPL MAIL BANCTEC ADDISON 8840.17 12-10-10 12-10-10 083 REG PMT-EFF DTE 194.46 PRINCIPAL 01-09-11 12-10-10 02 9.9900 12-10-10 DPL ACH CHA 8786.04 02-07-11 02-06-11 083 REG PMT-EFF DTH 54.13 PRINCIPAL. 02-09-11 02-06-11 02 9.9900 140.33 INTHRHST 02-07-11 DPL HAIL BANCTEC ADDISON DISCOVER BANK PAGE 0003 7ONSUMER/INSTALLMENT LOAN NOTE NBR -��i188-000 REASON- REQUESTED SHORT NAME CRISANTI TANIA PROC-THRU 4-24-2014 -----------------------------------HISTORY------------------------------------ * POST DTH EFF DATE TC1 TRANS DESCRIPTION AMOUNT TYPE NEW BALANCE DUB DATE PAID-TO TCZ I-RATE PSA 8656.51 03-07-11 03-05-11 083 REG PMT-EFF DTH 129.53 PRINCIPAL 03-09-11 03-05-11 02 9.9900 64.93 INTEREST 03-07-11 DPL MAIL BANCTEC ADDISON 85Z8.39 04-04-11 04-02-11 083 REG PMT-EFF DTE 128.12 PRINCIPAL 04-09-11 04-02-11 02 9.9900 66.34 INTEREST 04-04-11 DPL MAIL BANCTEC ADDISON 8406.29 05-03-11 05-03-11 083 REG PMT-EFF DTH 122.10 PRINCIPAL 05-09-11 05-03-11 02 9.9900 72.36 INTEREST 05-03-11 DPL MAIL BANCTEC ADDISON 8296.96 06-09-11 06-09-11 083 REG PHT-EFF DTE 109.33 PRINCIPAL 06-09-11 06-09-11 02 9.9900 85.13 INTHRHST 06-09-11 DPL IVR 8170.62 07-11-11 07-09-11 083 REG PMT-EFF DTE 126.34 PRINCIPAL 07-09-11 07-09-11 02 9.9900 68.12 INTEREST 07-11-11 DPL MAIL BANCTEC ADDISON 8036.54 08-05-11 08-05-11 083 REG PMT-EFF DTH 134.08 PRINCIPAL 08-09-11 08-05-11 02 9.9900 60.38 INTHRHST 08-05-11 DPL MAIL BANCTEC ADDISON 7919.07 09-09-11 09-09-11 083 REG PMT-EFF DTE 117.47 PRINCIPAL 09-09-11 09-09-11 02 9.9900 76.99 INTEREST 09-09-11 DPL IVR 7785.30 10-07-11 10-07-11 083 REG PMT-EFF DTH 133.77 PRINCIPAL 10-09-11 10-07-11 02 9.9900 60.69 INTEREST 10-07-11 DPL IVR - 7654.76 11-07-11 11-06-11 083 REG PMT-EFF DTH 130.54 PRINCIPAL 11-09-11 11-06-11 02 9.9900 63.92 INTEREST 11-07-11 DPL MAIL BANCTEC ADDISON 7529.44 12-09-11 12-09-11 083 REG PMT-EFF DTH 125.32 PRINCIPAL 12-09-11 12-09-11 02 9.9900 69.14 INTEREST 12-09-11 DFL IVR 7396.77 01-09-12 01-08-1Z 083 REG PMT-EFF DTH 132.67 PRINCIPAL 01-09-12 01-08-12 02 9.9960 61.79 INTHRHST 01-09-1Z DPL HAIL BANCTEC ADDISON 7260.86 02-06-12 02-06-12 083 REG PMT-EFF DTE 135.91 PRINCIPAL 02-09-12 02-06-12 02 9.9900 58.55 INTEREST 02-06-1Z DPL HAIL BANCTEC ADDISON DISCOVER BANK PAGE 0004 CONSUMER/INSTALLNENT LOAN NOTE NBR iO-1188-000 REASON- REQUESTED SHORT NAME CRISANTI TANIA PROC-THRU 4-24-2014 x-----------------------------------HISTORY------------------------------------" POST DTH EFF DATE TC1 TRANS DESCRIPTION AMOUNT TYPE NEW BALANCE DUE DATE PAID-TO TC2 I-RATS PSA 7125.85 03-07-12 03-07-12 083 REG PMT-EFF DTH 135.01 PRINCIPAL 03-09-12 03-07-12 02 9.9900 59.4S INTEREST _ 03-07-12 DPL MAIL BANCTEC ADDISON 6976.13 03-30-12 03-30-12 083 REG PMT-EFF DTE 149.72 PRINCIPAL 04-09-12 03-30-12 02 9.9900 44.74 INTHRHST 03-30-12 DPL MAIL BANCTEC ADDISON 6850.22 05-07-12 05-05-12 083 REG PMT-EFF DTE - 125.91 PRINCIPAL 05-09-12 05-05-12 02 9.9900 68.55 INTHRHST 05-07-12 DPL MAIL BANCTEC ADDISON 6719.33 06-08-12 06-08-12 083 REG PMT-EFF DTE 130.89 PRINCIPAL 06-09-12 06-08-12 02 9.9900 63.57 INTHRHST 06-08-12 DPL MAIL BANCTEC ADDISON 6576.22 07-06-12 07-06-12 083 REG PMT-EFF DTE 143.11 PRINCIPAL 07-09-12 07-06-12 02 9.9900 51.35 INTHRHST 07-06-12 DPL HAIL BANCTEC ADDISON 6432.02 08-03-12 08-03-12 083 REG PMT-EFF DTH 144.20 PRINCIPAL 08-09-12 08-03-12 02 9.9900 50.26 INTHRHST 08-03-12 DPL HAIL BANCTEC ADDISON 6291.99 09-04-12 09-03-12 083 REG PMT-EFF DTH 140.03 PRINCIPAL 09-09-12 09-03-12 02 9.9900 54.43 INTEREST 09-04-12 DPL HAIL BANCTEC ADDISON 6155.92 10-09-12 10-07-12 083 REG PMT-EFF DTH 136.07 PRINCIPAL 10-09-12 10-07-12 02 9.9900 58.39 INTHRHST 10-09-12 DPL MAIL BANCTEC ADDISON 6155.92 11-13-12 11-13-12 085 LATE FEE ASSESS 39.00 L/F ASSESS 11-09-12 00-00-00 00 9.9900 6155.92 12-12-12 12-12-12 085 LATE FEE ASSESS 39.00 L/F ASSESS 12-09-12 00-00-00 00 9.9900 6155.92 01-14-13 01-14-13 085 LATH FEE ASSESS 39.00 L/F ASSESS 01-09-13 00-00-00 00 9.9900 6155.92 02-12-13 02-12-13 085 LATE FEE ASSESS 39.00 L/F ASSESS 02-09-13 00-00-00 00 9.9900 6155.92 03-12-13 03-12-13 085 LATE FEE ASSESS 39.00 L/F ASSESS 03-09-13 00-00-00 00 9.9900 DISCOVER BANK PAGE 0005 "17SUMER/INSTALLMENT LOAN NOTE NBR 8-000 REASON- REQUESTED SHORT NAME Cki5ANTI TANIA PROC-THRU 4-24-2014 "-----------------------------------HISTORY------------------------------------* POST DTH EFF DATE TCI TRANS DESCRIPTION AMOUNT TYPE NEW BALANCE DUE DATE PAID-TO TC2 I-RATE PSA 6155.92 03-29-13 03-29-13 004 PUT ON NON-ACCR 291.08 NON-ACCRUAL INT 00-00-00 00-00-00 00 9.9900 03-29-13 PROCESSED BY! _00 03-29-13 03-29-13 088 CHARGE-OFF 6155.92 PRINCIPAL C/O 00-00-00 00-00-00 00 9.9900 03-29-13 AUTOMATED CHARGE OFF BY f _00 03-29-13 03-29-13 027 LATE FEE WAIVER 195.00 L/F WAIVED 00-00-00 00-00-00 00 9.9900 03-29-13 FT LATE FEE REVERSAL FOR CHARGH-OFF .00 03-29-13 03-29-13 035 FEE ASSESSED 195.00 FEE AMOUNT 00-00-00 00-00-00 00 9.9900 03-29-13 FT LATH FEE REASSESSMENT FOR CHARGE-OFF .00 04-02-13 04-02-13 003 INT RATE CHANGE _0000 NEW RATE 00-00-00 00-02-40 00 .0000 9.9900 OLD RATE 04-02-13 URF 3076 INTEREST RATE CHANGE .00 03-24-14 03-24-14 087 RECOVERY .00 PRIN RECOVERY 00-00-00 10-07-12 00 _0000 6.74 INT RECOVERY 03-24-14 URF5739 Charge Off Adjustment SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FLED-OFFiCE. Sheriff OF THE PROIHONOTAR'f w of cltlubt, Jody S SmithI' 2014 OCT 13 AM 10: 07 Chief Deputy ftt Richard W Stewart CUMBERLAND COUNTY Solicitor OFF}C OF FPF. f:A-tERIFr PENNSYLVANIA Discover Bank vs. Tania M Crisanti Case Number 2014-5760 SHERIFF'S RETURN OF SERVICE 10/06/2014 03:43 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 Laura Bennett, Mother, who accepted as "Adult Person in Charge" for Tania M Crisanti at 14 Riverview Drive, East Pennsboro, Enola, PA 17025. Jar\Mi-C) Av1lE DIMARTILE, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, October 07, 2014 RONNY R ANDERSON, SHERIFF (G.) CountySuito Sheriff, Teleosoft, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK No. 14-5760 CIVIL TERM Plaintiff/Petitioner vs. TANIA CRISANTI Defendant(s)/Respondent(s) PRAECIPE FOR JUDGMENT '-r ra Please enter Judgment in favor of Plaintiff and against Defendant, TANIA CRISANTV r tjure,' to answer the Complaint. (X) Amount due $6,642.00 TOTAL $6,642.00, plus costs and statutory interest from the date of Judgment. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intent ion to file this praecipe was mailed or delivered to the party against whom judgment is to be entered, and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE: t(•ILA 1� Amy F.`I oyle, Esquire, ID #87062 Philip Warholic, Esquire, ID #86341 Jaffe & Asher, LLP 11 East Market St., Suite 102 York, PA 17401 717-885-0718 / 877-202-9420 717-885-0726 (facsimile) Counsel for Plaintiff NOW, \ivt,)U . I `1 , 2014, JUDGMENT I ELATE D BOVE Prothonotary/O'er;Civil Division BY: Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK No. 14-5760 CIVIL TERM Plaintiff/Petitioner vs. TANIA CRISANTI Defendant(s)/Respondent(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above -captioned matter, and that to the best of my knowledge, information and belief, Defendant TANIA CRISANTI, above-named, is over 21 years of age; is last known to reside at 14 RIVERVIEW DR, ENOLA PA 17025, County of CUMBERLAND, State of Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Service members Civil Action Relief Act and its Amendments. Date: t t . i LA Amy F. ! •y1; quire, ID #87062 Philip Warholic, Esquire, ID #86341 Jaffe & Asher, LLP 11 East Market St., Suite 102 York, PA 17401 717-885-0718 / 877-202-9420 717-885-0726 (facsimile) Counsel for Plaintiff On this, the 14 day of 00.1/Oril , 2014, before me, the undersigned officer, personally appeared Amy F. Doyle, known to me to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cortney Moreland, Notary Public City of York, York County My Commission Expires Nov. 23, 2017 MEMBER, PENN5fl lAM4 . a49O I.TION OF liOTARIES NEW YORK OFFICE 600 THIRD AVENUE NEWYORK, NY 10016-1901 TANIA CRISANTI 14 RIVERVIEW DR ENOLA PA 17025 JAFFE Et As H ER LLP ATTORNEYS AT LAW ESTABLISHED I 974 WWW.JAFFEANDASHER.COM October 31, 2014 TEL 2 I 2-687-3000 TOLL FREE 888-625-9895 FAx 212-687-9639 RE: DISCOVER BANK vs. TANIA CRISANTI Docket No. 14-5760 CIVIL TERM Dear Tania Crisanti: Enclosed herein please find a 10 -Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Amy . Doyle #87062 Jaffe & Asher, LLP 11 East Market St., Suite 102 York, PA 17401 adoyle@jaffeandasher.com (717) 885-0718 (877) 202-9420 (717) 885-0726 (facsimile) Enclosure This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose. CONNECTICUT OFFICE I I 00 KINGS HIGHWAY EAST, SUITE 3C FAIRFIELD, CT 06825 TEL 203-583-34 I 4 NEW JERSEY OFFICE 80 E RIDGEw000 AVENUE PARAMUS, NJ 07652 TEL 201-977-4329 PENNSYLVANIA OFFICE I I EAST MARKET STREET, SUITE I 02 YORK, PA I 7401 TEL 71 7-801-1523 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK No. 14-5760 CIVIL TERM Plaintiff/Petitioner vs. TANIA CRISANTI Defendant(s)/Respondent(s) TO: TANIA CRISANTI 14 RIVERVIEW DR ENOLA PA 17025 Date of Notice: October 31, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 Co. Bar Association 32 South Bedford Street Carlisle, PA 17013 800/990-9108 By File: 10008587 & CUBS: 171859 Amy F. Doyle #87062 Jaffe & Asher, LLP 11 East Market St., Suite 102 York, PA 17401 adoyle@jaffeandasher.com (717) 885-0718 (877) 202-9420 (717) 885-0726 (facsimile) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK No. 14-5760 CIVIL TERM Plaintiff/Petitioner vs. TANIA CRISANTI Defendant(s)/Respondent(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise residence of Plaintiff is: DISCOVER BANK 2500 LAKE PARK BOULEVARD WEST VALLEY UT 84120 and certify that the last known address of the within Defendant is: TANIA CRISANTI 14 RIVERVIEW DR ENOLA PA 17025 Amy F. fie, Esquire, ID #87062 Philip Warholic, Esquire, ID #86341 Jaffe & Asher, LLP 11 East Market St., Suite 102 York, PA 17401 717-885-0718 / 877-202-9420 717-885-0726 (facsimile) Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK No. 14-5760 CIVIL TERM Plaintiff/Petitioner vs. TANIA CRISANTI Defendant(s)/Respondent(s) NOTICE OF JUDGMENT (X) Notice is hereby given that a Judgment in the above -captioned matter has been entered against you in the amount of $6,642.00 on 'NPV , i 1 , 2014, plus costs and statutory interest from the date of Judgment. (X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. If you have any questions regarding this Notice, please contact the filing party. Amy F. Do , squire, ID #87062 Philip Warholic, Esquire, ID #86341 Jaffe & Asher, LLP 11 East Market St., Suite 102 York, PA 17401 717-885-0718 / 877-202-9420 717-885-0726 (facsimile) Counsel for Plaintiff (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: TANIA CRISANTI 14 RIVERVIEW DR ENOLA PA 17025