HomeMy WebLinkAbout14-7296 Supreme Cou ennsylvania
For Prothonotary Use Only:
Cour. ' f An leas
CZ .It Docket No: 14
CUCounty
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadings or other o ers as required by law or rules of court.
S Commencement of Action:
® Complaint ElWrit of Summons F-1Petition
E
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff's Name: Lead Defendant's Name:
T DISCOVER BANK ROBERT GENET
Dollar Amount Requested: within arbitration limits
Are money damages requested? 0 Yes El No (gym) outside arbitration limits
0
N Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJAppeal? ❑ Yes No
A Name of Plaintiff/Appellant's Attorney:Zwicker&_Associates,P.C.
❑ 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 Plaintiff ❑ Administrative
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Agencies
❑ Motor Vehicle ® Debt Collection:Other ❑ Board of Assessment
❑ Nuisance ❑ Board of Elections
❑ Premises Liability
El Product Liability(does not include El Dept.of Transportation
mass tort) El Employment Dispute:Discrimination [:] Statutory Appeal:Other
S ❑ Slander/Libel/Defamation ❑ Employment Dispute:Other
❑ Other:
E ❑ Zoning Board
MASS TORT El Other El Other
C ❑ Asbestos
T ❑ Tobacco
❑ Toxic Tort-DES
I ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory
0 El Other
❑ Eminent Domain/Condemnation Arbitration
❑ Ground Rent ❑ Declaratory Judgment
N ❑ Landlord/Tenant Dispute ❑ Mandamus
❑ Mortgage Foreclosure:Residential ❑ Non-Domestic Relations
PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure:Commercial Restraining Order
❑ Dental ❑ Partition ❑ Quo Warranto
B ❑ Legal ❑ Quiet Title ❑ _Replevin
❑ Medical ❑ Other: ❑ Other.
❑ Other Professional:
Updated 1/1/2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
DISCOVER BANK,
Plaintiff
vs. Civil Action No.
ROBERT GENET ,
Defendant(s)
NOTICE TO DEFEND—CIVIL
You have been sued in Court. If you wish to defend against the claim set forth in the following
papers, you must take action within twenty (20) days after this complaint and notice are served
by entering an appearance personally or 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 any 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 COUNTY BAR ASSOCIATION c
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
LAWYER REFERRAL SERVICE: -
PENNSYLVANIA LAWYER REFERRAL SERVICE
800-692-7375 : '
4f
&tll op59xv
P,-# 3/Z/;;yw
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
DISCOVER BANK,
Plaintiff
c/o DB Servicing Corporation
CL Rec. 2500 Lake Park Blvd.
West Valley City, UT 84120
Civil Action No.
vs.
ROBERT GENET ,
Defendant(s)
ROBERT GENET
305 ELMWOOD AVE
MECHANICSBURG, PA 17055
COMPLAINT IN CIVIL ACTION
1. Plaintiff is a FDIC-insured Delaware State Bank.
2. One or more of the Defendant(s)reside in CUMBERLAND County,Pennsylvania.
COUNT I—BREACH OF CONTRACT
3. At the request of Defendant(s),Plaintiff issued an account for credit services to Defendant(s)with
an account number ending in#8169 and Defendant(s)was provided with the terms and conditions
applicable to the account. See record of the account terms and conditions attached hereto as
Exhibit"A".
4. Defendant(s) accepted the terms and conditions of the account by using the credit extended.
Records of the account statement(s) for the credit account is/are attached hereto, marked Exhibit
"B"and made a part hereof.
5. Defendant(s) breached the terms and conditions of the account by failing to pay the balance due
and/or make the required monthly payment.
6. The balance due and owing to Plaintiff is$20,694.78.
COUNT II—ACCOUNT STATED
7. The averments set forth in Paragraphs 1 to 6 above are incorporated by reference thereto as
though herein set forth at length.
8. An account was duly stated between Plaintiff and Defendant(s).
9. Plaintiff sent periodic statements to Defendant(s).
10. The statements stated the balance and any debits and/or credits for period covered by the
statement.
11. Defendant(s)made payments on the account or retained statements without payment.
12. The balance due and owing to Plaintiff is$20,694.78.
Page 1 of 3
WHEREFORE, Plaintiff demands Judgment against Defendant(s) for the sum of $20,694.78
together with costs.
ZWICKER&ASSOCIATES, P. C
Attorneys for Plaintiff
A Law Firm Engaged in Debt Collection
DATE: --� �� t� BY:
lATHAN CAWL , ESQ.
VIA Bar Id No. 79884
500 OFFICE CENT DRIVE
FORT WASHING , N, PA 19034
(877)297-1183
Page 2 of 3
VERIFICATION
,Sec-iali�f-
(Name) (Title)
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 services. As
the servicing affiliate,DB Servicing Corporation, performs a variety of services for, or on behalf
of Discover Bank including, business management services in support of Discover Bank
business lines,including without limitations, credit cards,deposits,personal loans, student loans,
Customer Service, Collections, and other support services. The accounts may be forwarded to
attorneys who file suit on behalf of Discover Bank. Both DB Servicing Corporation and
Discover Bank are wholly owned subsidiaries of Discover Financial Services, an independent,
publicly traded company.
Date: pec Zo
Name
Defendant(s): ROBERT GENET
Account number: ending in 8169
Page 3 of 3
Loan#8169
February 07,2012
ROBERT A.GENET
305 ELMWOOD AV
MECHANICSBURG,PA 17055
Dear ROBERT A.GENET,
Welcome to Discover®Personal Loans! We're pleased to confirm your loan has been approved in the amount of
$20,000.00. Your loan funds have been disbursed to you and/or your creditors as requested. Please allow up to 10 days for
receipt and continue to make payments to your creditors to avoid late fees.
Your Discover Personal Loan is now working for you to provide the plan and the resources you need to achieve your financial
goals. Your first of 84 fixed monthly payments of$386.46 is due on March 11. Each month,you'll receive your statement
approximately 20 days before your payment is due.
And there's more good news! The free DirectPay plan you selected when you applied has been activated and your first
monthly payment will be debited directly from the bank account you specified on March 11 (may take 1-2 days to post at your
bank). You will continue to receive your monthly statement for informational purposes.
Want another smart option for your Discover Personal Loan? Affordable Discover Credit Protection lets you put your loan
payments on hold in the event of certain covered events such as job loss or disability. To learn more,please see the form at
the bottom of the next page,or call one of our Credit Protection Specialists at 1-877-531-1950.
If you have any questions,please visit our Web site at DiscoverPersonalLoans.com or call our Personal Loans Customer
Service Center at 1-877-256-2632. Thank you again for choosing Discover Personal Loans.
Sincerely,
Maureen Powers
Director,Discover Personal Loans
p
This space intentionally left blank.
HIBEXi i A
TRUTH—IN—LENDING DISCLOSURES
Creditor: Discover Bank—Wilmington, DE 19850 Loan X8169
Borrower(s)ROBERTA.GENET-305 ELMWOOD"-MECHANICSBURG,
PA 17055
F4et
PERCENTAGE FINANCE CIL RGE Amount Financed Total of Payments
RATE
your credit as a The dollar amount the The amount of credit The amount you will have paid
credit will cost you: provided to you or on after you have made all
your behalf payments as scheduled:
$12,462.64 e. $20,000.00
$32,462.64 e
Your payment schedule will be:
Number of Pa ents Amount of Pa eats When Pavments are Due
847 $386.46 a Monthly beginning March 11 e
Late Charge: if we do not receive the full amount of any monthly payment by its due date,we will.charge
you a Late Fee of$39.00 and we may increase your interest rate to a Default Rate up to a
maximum of 28.99%. Your Default Rate is determined based on factors such as your current
interest rate,payment history with as and your general credit history.
Prepayment: If you pay off early,you will not have to pay a penalty and will not be entitled to a refund
of part of the finance charge_
Further terms: See your Loan Agreement for any additional information about nonpayment,default,any
required repayment in full before the scheduled date,and prepayment refunds and penalties.
e means an estimate
Your Interest Rate is:14.99%
***See reverse for Itemization of Amount Financed***
Protect your Discover Personal Loan account with optional Discover Credit Protection.
You can enroll in Credit Protection for a monthly fee of only$38.64 and be ready for unexpected events.
Learn more about Discover®Credit Protection. v
Prepare for the unexpected --with Discover®Credit Protection Premier.
Put your Discover Personal Loan payments on hold for During that time,you'll make no loan payments and incur no finance
up to two years if you: charges,late fees or Credit Protection fees. Credit Protection Premier
•Lose your job may also cancel your loan balance up to$25,000 in the event of your
permanent disability or death*.And Credit Protection Premier costs
•Become hospitalized just$38.64 per month($463.68 per year).
•Become disabled(accident or illness)
•Take a voluntary leave of absence
•Experience a federal or state disaster
For more information and to enroll,please call one of our Credit Protection Specialists at 1-877-531-1950.
Please see reverse side for Important Information.
6169
ROBERT A. GENET,
Itemization of the Amount Financed totaling: 11ggoo.00 Loan#9�8169
Amount paid to you directly via check
$0.00
PEOPLESSANK,A CODORUS VA Account Ending in 6379
$20,000.00
DISCOVER®CREDIT PROTECTION PREMIER
IMPORTANT INFORMATION
Discover Credit Protection is provided by Discover Bank and includes both debt suspension and debt cancellation benefits.Discover Credit Protection is not insurance.
This product is optional.Your purchase of Credit Protection is optional.Whether or not you purchase Credit Protection will not affect your application for creditor the terms of any existing you have with us.
Amount of fee. The monthly fee for Credit Protection is$38.64 per month 5463.689 credit agreement
you finance. This fee will be included in the monthlyInstallmenPayments due on Per year), Your total yearlyycost P period.
Protection will depend on the term tyour loan,your APR and the amount
TermP Y your Loan for each month bills
tinue
we
Cre
30 datnation of ys of your enrotllment date,v Enrollment
refund will
yournCredit Prountil
tectiu nrfee.We may cancel Credit Protection n aour t anIs y time,bufull.
t will not reduccee benefits you etre alrrefady Protection any time.if you cancel within
Change in terms.We may change the Credit protection terns and fees at any time. if we make a change that is unfavorable to you or involves an additional charge,we will give you advance written
notice and a reasonable opportunity to cancel without penalty.
Explanation of debt suspension agreemenL M Credit Protection is activated,your duty to pay the loan principal and finance charges to us is only suspended for a period Of up to 24 billion
must fully repay the loan after the period of suspension has expired.Schadu ed moot installment payments will resume when benefits have ended,and
t month installment payments for which you received Credit Protection benefits. 9 Periods. You
your loan term will be extended for the number
Debt cancellation.If you Pass away or become permanently disabled while enrolled,the balance on your Loan as of the date of death or permanent disability,as applicable,will be cancelled,UP to
$25,000.
Eligibill requirements,conditions and exclusions.There are eligibility requirements,conditions and exclusions that could prevent you from receiving benefits under Credit Protection.A complete
explanation is in the following pareggraphs of the Credit Protection Terms and Conditions:paragraph 3,"Important Limitations on Benefits",and the paragraphs that explain the conditions and exclusions for
the particular everds,paragraph 4, Involuntary Unemployment',paragraph 5,'Short-Tenn Disability paragraph 6.•Leave of Absence"paragraph 7,"Federal or State Disaster",paragraph 8,
'Hospitalization'paragraph 9,"Retired,Self-Employed and Unemployed Borowere`,and paragraph 10,'Balance Cancellation".We will send you information including the Terms and Conditions before
you have W pay. Please read it carefully_
Debt cancellation is not offered or available to residents of AK IA,NV,OR,RI,TN,WI,PR,GU,VI or any other state or territory where it is regulated as insurance.
02009 Discover Bank,Member FDIC
Disco
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DISCOVER BANK PAGE 0001
CONSUMER/INSTALLMENT LOAN
NOTE NBR 169-000 RBASON- REQUESTED
SHORT NAME GENET ROBERT REASON-
8-13-2014
*------------BALANCE DATA-------------* ROBERT A GENET
NOTE AMOUNT 20,000.00 305 ELMWOOD AV
PRINCIPAL BALANCE •00 MECHANICSBURG PA 17055
INT BALANCE 1,366.91
PAYOFF AMOUNT
AS OF 8-12-14 20,694.78
PERCENTAGE SOLD .000000000t
CONTACT-
------------INTEREST DATA------------ TITLE-
INTHREST RATS .0000 HOME PHONE 717-691-0801
DAILY INT. FACTOR .000000 BUS PHONE 717-846-5000
INTEREST PAID YTD 31.49 OFFICER TLR DEALER 00000
GUARANTEE CODE 2
ACC/YR BASH ACT-365/366 *-------------CREDIT DATA------ ---x
PAST DUH Cl 1 PAST DUH 30 DYS 1
`-O-------------DATES-----------------x PAST DUH C2 1 PAST DUH 60 DYS 1
NOTE DATE 02-07-12 PAST DUH C3 0 PAST DUH 90 DYS 1
LAST RENEWED 00-00-00 TOTAL PAST DUH
NEXT MATURITY .00
02-11-19 OLDEST PMT DUE DATE 00-00-00
ui
LAST ACTIVE 03-Z4-14 LOAN FEES DUB
INTHRBST PAID-TO156.00
08-10-12 LATH FENS DUH .DO
LAST PRINCIPAL REDUCTION 01-31-13 CLASSIFIED/RISK
---------------------------EXTENSION/RENEWAL COUNTERS-------------------------
NBR OF EXTENSIONS
TO-DATE MTD YTD LAST TRAM DATE
'
NBR OF SKIP PAYMENTS 00-00-00
NBA OF DEFERENTS 00-00-00
NBR OF RENEWALS 00-00-00
NBR OF WORKOUT RENEWALS 00-00-00
NBR OF DUH DATE CHANGES 00700-00
00-00-00
*-----------------------------------HISTORY------
POST DTH EFF DATE TCI TRANS DESCRIPTION AMOUNT TYPE
DUH DATE PAID-TO TC2 I-RATE PSA NEW BALANCE
02-07-12 02-07-12 033 IST DISBURSE20000.00
00-00-00 02-07-12 00 14.9900 20000.00 PRINCIPAL
03-09-12 03-09-12 083 RHD PMT-EFF DTH19867.47
03-11-12 03-09-12 02 14.9900 132.53 PRINCIPAL,
03-09-12 DPL FISBRV DPP 253.93 INTEREST
04-11-12 04-11-12 083 REG PMT-EFF DTH19749.53
04-11-12 04-11-12 02 14.9900 117.94 PRINCIPAL
04-11-12DPL PISHRV DPP 268.52 INTHRBST
05-11-12 OS-11-12 083 REG PMT-EFF DTH19605.73
05-11-12 OS-11-12 02 14.9900 143.80 PRINCIPAL
OS-11-12 242.66 INTEREST
DPL FISBRV DPP
V"41UVAR BANK
NOTE NBR flINJI�.. CONSUMER/INSTALLMENT LOAN PAGE 0002
SHORT NAME GHNr BERT- 000
REASON- REQUESTED
PROC-THRU 8-13-2014
POST DTH EFF DATE TCl TRANS DESCRIPTIONORY---________
DUH DATE PAID-TO TC2 I-RATE PSA AMOUNT TYPE
NEW BALANCE
06-11-12 06-11-12 083 REG PMT-EFF DTH
06-11-12 06-11-12 0214 137-54 PRINCIPAL 19468-19
DPL ,9900 PL FISHRV DPP 248.92 INTEREST
07-11-12 07-11-12 083 REG PMT_HFF DTH
07-11-12 07-11-12 0214 147.25 PRINCIPAL 19320,94
07-11-12 -9900
DPL FI58RV DDD 239-21 INTEREST
08-10-12 08-10-12 083 REG PMT^8PF DTB
08-11-12 08-10-12 02149,07 PRINCIPA19171.87
08-10-12 14.9900 L
DPL FISERV DPP 237-39 INTBRHST
09-11-12 09-11-12 083 REG PMT-$FF DTE
09-11-12 09-11-12 02 13S-19 PRINCIPAL 19036.68
09-11-12 14-9900 '
DPL FISHRV DPP 251.27 INTEREST
09-17-12 09-11-12 037 PAYNT REVERSAL
09-11-12 08_10-12 00 135,19 PRINCIPAL 19171,87
14
09-17-12 .99D0 N
WRRING ACHRTNS 386,46 251.27 INTEREST PAID
R02 9-14,12
10-15-12 10-15-12 085 LATE FHB'ASSESS
10-11-12 00-00-00 00 14,9900 N 39.00 L/F ASSESS 19171-87
12-14-12 11-14-12 085 LATH FEE ASSESS
11-11-22 00-00-00 00 14 39.00 y F 19171.87
.9900 ! ASHSS
12-14-12 12-14-12 085 LATE FEE ASSESS
12-11-12 00-00-00 00 14,9900 39,00 L/F ASSESS 19171.87
01-14-13 01-14-13 OBS LATH FEE ASSESS
01-11-13 00-00-00 0014.9900 39.00 L/F ASSESS 19171.87
01-31-13 01-31-13 004 PUT ON NON-ACCR
00- - 00-00-00 00 1366.91 NON-ACCRUAL INT 19171.87
01-3131-1313 14-9900
PROCESSED By_
01-31-13 01-31-13 088 CHARGE-OFF
00-00-00 00-00-00 OD 14.9900 19171.87 PRINCIPAL C/0 00
01-31-13 AUTOMATED CHARGE OFF BY
01-31-13 01-31-13 027 LATE FEE WAIVER
00-00-00 00-00-00 00 14.9900 156,00 L/F WAIVED •00
01-31-13 FT LATH FEE REVERSAL FOR
CHARGE-OFF
01-31-13 01-31-13 035 FHH ASSESSED
00-00-00 00-00-00 00 14,9900 156.00 Fgg -00
01-31-13 AMOUNT
FT LATH PH$ REASSESSMENT FOR CHARGE-OFF
Ml"Wnx 2lANK
NOTE NBR CONSUHHR/INSTALLHHNT LOAN PAGE 0003
169-000
SHORT NAHHA GENET ROBERT REASON- RHOUHSTHD
PROC-THRU 8-13-2014
-----------------------------------HISTORY----------- ___ _
POST DTE EFF DATE TC1 -----
TRANSANS DESCRIPTION -----
DUH DATE PAID-TO TC2 I-RATE PSA AHOUNT TYPE NEW BALANCE
02-04-13 02-04-13 003 INT RATE CHANGE
00-00-00 00-03-63 00 .0000 NHW g$Tg •00
02-04-13 0000 14.9900 OLD PATH
URF 3076 INTEREST RATE CHANGE
03-24-14 03-24-14 087 RECOVERY
00-00-00 08-10-12 00 0000 00 PRZN RECOVERY 00
03-24-14 31.49 INT RECOVERY
URF5739 Charge Off Adjustment
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
DISCOVER BANK,
Plaintiff
VS.
Civil Action No. �- aq Cut'
ROBERT GENET
Defendant(s)
PRAECIPE FOR ENTRY OF APPEARANCE „
To the Prothonotary:
Enter my appearance on behalf of Plaintiff. 4 a
C-1
Papers may be served at the address set forth below
DATE: December 15, 2014
WICKER&ASSCO ATES,—P. (C
Attorneys for Plaintiff
A Law Firm Engaged in Debt Collection
Jonathan P. Cawley, Esq
PA Bar Id No. 79884
500 Office Center Drive, Suite 400
Ft. Washington, PA 19034
877-297-1183
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
•
Ronny R Anderson
Sheriff-;}�'�t(_?�i
�ktitkr c+t Ciordier� jr
Jody S Smith PF141F141G }
Chief Deputy * . .i� RE 1 14
Richard
Solicitor Stewart T CIJI'S ERi.r�t �- C,``
Wr �,�
PtENSSYLVAMIi.
Discover Bank
vs.
Robert Genet
Case Number
2014-7296
SHERIFF'S RETURN OF SERVICE
01/07/2015 08:02 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Robert Genet, but was unable to locate the Defendant
in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at
305 W. Elmwood Avenue, Mechanicsburg Borough, Mechanicsburg, PA 17055. Deputies were advised
by the defendant's estranged wife that the defendant moved to Montecito Sequoia Lodge, P.O. Box 848,
63410 Generals Highway, Kings Corner National Park, CA 93633.
SHERIFF COST: $32.00
January 08, 2015
(c) CouritySuite Shedd, Telaasat
SO ANSWERS,
RONZANDERSON, SHERIFF