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