HomeMy WebLinkAbout05-4006IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
Vs.
DENISE B CREE
Defendant
No:
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 2718
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
04141059 C A Pit KMJ
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
DENISE B CREE
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, is a corporation with offices at 3311 MILL MEADOW DR.
HILLIARD , OH 43026
2. Defendant is adult individual(s) residing at the address listed
below:
DENISE B CREE
134 S 24TH ST
CAMP HILL, PA 17011
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number 6011300620047736 . A copy of
Plaintiff's Statement of Account s attached hereto, marked as Exhibit
"A° and made a part hereof.
4. Defendant made use of said credit card and currently has a balance
due and owing to Plaintiff, as of July 28, 2005 , in the amount of
$3726.13
5. Defendant is in default by failing to make payments when due.
6. Plaintiff avers that the Agreement between the parties provides
that Defendant will pay Plaintiff's attorneys' fees.
7. Plaintiff avers that such attorneys' fees will amount to $500.00
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due to Plaintiff.
Wherefore, the Plaintiff prays for Judgment in its favor and
against Defendant , DENISE B CREE individually , in the amount of
$3726.13 with interest at the legal rate of 6.0001 per annum from date
of judgment plus attorneys, fees of $500.00 , and costs.
WE WEINBERG & REIS CO., L.P.A.
43 eventh Avenue, Suite 2718
P t burgh, PA 15219
(4 ) 434-7955
F 412-338-7130
4141059 C A Pit KMJ
This law firm is a debt collector attempting to collect this debt for
our client and any information obtained will be used for that purpose.
Va J%'-v `!K payment due date
CARD March 12,20M
Private ism minimum payment due
$536.00
DENISE B CREE
134 S 24TH ST
CAMP HILL PA 17011-4609
new balance account number 6011 3006 2004 7736
$3,746.13 enter amount andosed below
Maass make on"* payable to Private Issue.
You are ovanimit. Please pay your mirdmum payment
plus $ 746. 13.
SimpgN and Savel Use your DlsooveiO Caret to
pay ootttt high-rate balances today. You can save
money and consolidate your debt Into one
convenient payment. Call 1-800.767.7389 to see It
a special Balance Transfer offer Isavailable foryou.
PO BOX 15254
WILMINGTON DE 19886-5254
u r?? ?r ?n ?u (r ?u?u??n r?r?u r? r?r?r) u?u?r? r (u ?r r) u?? r
Address ortelephons change? Please print change 1n the apace above.
000006011300620047736037461300000000053600
Closing Date: February 13, 2002 page 1 of 2
Rate Advantage
Current Rate Advantage 19.99%
Anniversary date: January13
Private Issue Account Summary
account number 6011 3006 2004 7736 previous balance $3,626.06
cred tt limit $3,000.00 payments and credits 0.00
credit available $0.00 purchases + 58.00
cash credit limit $1,500.00 cash advances + 0.00
cash wedit available $0.00
balance transfers + 0.00
FINANCE CHARGES + 62.07
new balance = $3,746.13
You may be able to avoid Periodic Finance Charges, see the
reverse side for dL tells.
08 SPIN6801 0000063
Transactions
trans. post
data date
Previous statement balances FINANCE CHARGES: OLD BALANCE $ 0.00
FINANCE CHARGES: CASH 0.00
FINANCE CHARGES: PURCHASES 681.48
FINANCE CHARGES: BALANCE TRANSFERS 0.00
PRINCIPAL: OLD BALANCE 0.00
PRINCIPAL: CASH
PRINCIPAL: PURCHASES
PRINCIPAL: BALANCE TRANSFERS
Train data Post dale
Feb 13 Feb 13 OVERLIMIT FEE
Feb 13 Feb 13 LATE FEE
0.00
2,934.56
0.00
29.00
29.00
EXHIBIT
Q
Please see roltowma raoe faaddidonel inmrma#on.QasitloRS7 Call i-M 4P1-CARO(1-600.474.2,'
..r
DISC xvf Eff -
1 CLASSIC
.t
i
-' IMPORTANT INFORMATION
ABOUT YOUR ACCOUNT
CA"MEMIER AGREEMENT -
The terms and Condrtioris of your Acmunt indud'mg
how we mkulatr finance carper our feet and an
Asbiiration of Dbputec action. You hive the right to L
• rryeR the erbftation prorislon whh respect to your
new Attaunt whhin 30 dsys after raceiving your Cart(
-' Ar erphsinrd in the 'Acceptance of •AgreemrnY
section ........................ SEE PAGES 7 - 14
PRNACYPCVCY
A sun mart' of the personal infontation.we roiled
when R may be dyed with other; end how we
ufnguard the confiderrtiaT4y and security of
information. You may han7t our sharing of such
information wRh others......... SEE PAGES 74 - 77 1•
gru_wG 8167.175 -
Impor7ant information about yoto rights and our
rerponsibi Nei under the Fair Credit a Ming Art .....
.............................SEEPAGES 17-73
CASFISACK SONisS' TERMS AND CD MMONS
The tentu and Wnd1thm of the Cashback Some
award propr anv inducing a desci;don of how your
award is mkulated and how to redeem it .........
.............................SEEPAGES 73.27
DESCRIPTION OF COVERAGE
The terms and rondhior's of the Scheduled Air 7ravel
Atddent Insurance that it provided at no Charge to
you when you use your Card to purdtaTe sklme
tickets ..................':..... SEE PAGES 21 -24
O ZM* Dkz Xwk Mw bw FDrC
saspC7D4W1tt1 ! .
EXHIBIT
B
i
s a-?...:.-:.•.•"....w.e... i..s:...'.? ?. ?....: '.ter' +t-..r,:r.^-:i-ut
1Ga' z
-?.._u.? ? J. k' .. •sc?ii.i?
_ .r
indoeGtyr 3) hdectiDns ofmy kindtregecdless ??ibp
esrsp[ baewidinfecti?rs that vq ¢e[tlytaraed
ptomaine pD6Dn(717 Dy Mac'crderteln+t;rx.w?v9d i
and in the abecm of any undedyinp kl:neem
tom,dit6n indud1eg IM not-funWiD dia .4) m
xn m?ptumrv to clan TA a fA?r "51 vuJr? W 3tt a vat
undedvetS: or (? trsv`ei ev;ffrQhi; ..PAP.,
acrid naviQetioq et a p11 Dperjttar igb;2w memt
I.IMtL47'IDNS,SBenef"its _wi?l,dnlyba f+a'?+ndn
TMmber iGSDUrit tF+e ?i?-,{?JdWnden,.N'I?ICfi.Tf?
on a tip CarrS? FiR T¢fels wendv6y.'"?ii?e'?d ?? j-:?
fir %Nch tt.e ticket;j4i npuriMied'wri v fTi>;urr>t
CDmplnv prov¢iors pertaining m this plan of hwMAre an
contained in Poky P902gD7t laved by National union F"ve
incunnre Company of MThburgh PA with offices in New YDrt,
W. The prenuum for this imuram k paid by D"rstover Financial
Sec' mt, Ind out of income derived from ft uedrt card
DpentiDrs.
i
Piease reed this Dntriptiph of Cmertpe. Keep it in.a safe place 1
whh your other kaurante documents. •fhk >--;rApptTivn of
Coverapt (Form kumber S3D3aSD'b0 . it riDY`.i vo u;n"U
knvrarKe but k simp)yin 1nfDfmativi rutimentctb eiyfi•efigrble
Individual of the prindyal prw;imti'cfut msunn?e'e+Fiie in
effe L
if i wnflici Wru between a statement in this D c iptim of
Coverage and any prw'sions in the Perry. the Polity will gomm '
Claim adminatered by: AEH Claims Department P.D. Sax j
157DI, Wilmington, DE MSDwMl, fSOO) 557-Mk . I
.5, .f
CARDMEMSER AGREEMENT
Pbese nod thk Agmarutm nrefuily bet"' udnR your
D•bwne Card A=Wft It mnlaba the terns and magfws of
'ek prw?' to you A the vvetrt at my d"df cm thk
Apretment shel iwdrei.
Fh mpbm yov privagL See the hrh' Sactkm m page 10 end
wa privacy Miry for adddmw wwmatim,
The Arbbratim of Dkputes Section Dn FOY' 12 bdrrdes a waiver'
of a number of rig M kdu&v the right m e pvy trial
CARDMEAf6F]I /.faRFfhfEh'f
Agreerhent Tam .................................. 2
AaeFrarm of Agreen Bent .......................:... . 2
L1te of Your Amourd .......... ....................... 2
Atdrorced Users ..................................
VneuOffked We ......................•........,.. J
CreditUrrA-AwMbltCredit.......................... S
homke tD ray ..................................... 4
mbrrthly MR Statement ............................ A
MDrdriy )eymert Dptiota ............................ e
- efmimum Monthly reymtrt .......................... S
• Credit sabrras .................................... S
6abnm TtarOm ................................... S
Finance choper .................... :............... S
hrbodk FlrA= fhargci ............................. 6
Defaul We Man ............... r..................:.9
"^ _.~... Cady Advance Twoc6m The Finance Ma t
.6abmv Tnn{fer Tr%mbctien Fee Fiona turps ......... J
W"mum Fk*m CMrga ............................ J
Retuned Chink Fee..r .............................. D
ketemed D'scovc Card Cheri Fee ..................... f
Stop Paymers Fit .................................. 9
Late Fee ....................... .................... 9
PeybyPtrone Fee .................................. 11)
Remarth Fee.....:... ............................. 1D
Over6mR Fee . . ID
..............
Ddeutt•Aaelera$oa{a1leNon Cots .................. 1 D
' Can?cepatiwr ...................................... 10
Mscy......................
Electronic Cemmuniatiors ........................... 11
Credit Avdrorhatiors ............................... . 1 t
Chvge of Terns ................ -- ......... ..... 11
• OArTe of Addren ................................. 12
Aalgemwt of A=wn ............................. 12
Arbfm6n of Dkyvtea ............................. 12
C.Mrsame vhth hstwwt Rate L•rmitationr ............... 13
%pverKm; Law .................................. .. 15
-1-
i i
•• ?+. .?.:?.i.r w..rvw?/.?b:?iii?.xs_mn?.v_r. _..-.-...e-.?._?ee v..Lm 4?•?._?+a_ i..r.e-e r.r?.
w
A6?.EEMENT 7ERMS. The word -Account' mum your
Disc" Card Account The word 'Card' meant any one or more
Discover Cards issued to you or someone else with your turhori
ruction The woh i'you', your'. or 'purr' refer to, in addition
to )%k the Cardmambis; hbz mmmracluilN 1610 do ft other person or Agra merR The words 'we't
'Le and 'Our' tefer to Dixs v bank. the issuer Df you
D)srovar Card. The words 'Authorimd User mean any person
whom you authortre to use your Amount or a card. whether you
ntottiy is or noL The wDrck Fricing Schedule' mean the
rd and rst)np the Finance
donvnerd rcmm Mo.
Chap rates that your Account The Pricing ScAcdute is
Part Agreement '
ACCEe UAa OF ASREEMEWE The use of your Atcoutt Or a Ca
by you or an Authorized User or your failure to camel yD
Account within X days after retaking a Card, =am you acre
this Agreement it dodmg the Arbitration OF Disputes
pro vns r
on page 12 Your me% hmvvK rejed the Arbtnrlim
Disputes section by provudmg sea a nodC1 of rejection %* hire
drys after rcceMnp a Card, at the following address: D'
Card P D. Box 303k Sell iota Crt1s UT Ba13D-ML d you we
iueviocaiy nub' to arbitration with r?psct m any Accw
the r ht to M. arbivatim will not appy tD you use the e
OM the A¢wmi he been reopened or rettrement Cards a
sent to you. Your ejection notice must nchrde your nam
occurs. telephone numiieG Account number and ciggnnatwe an
mud not be sent with a bites cometpondence Calling w to
hndhate that you ejed the Arbitration of Dispvtn section
sending a rejecsan native in a marmer or forma that does compy with an applicable requirements it kuuff¢krt notice.
not current Authorized Userm use your Account or a Grit, you must
order to wke, we esquire that the notice
of dtidr??aed draw ?hahu oor rParty. uail/ Itio
Yaw rag porwbinties
undo this Agreement or your Dbnga u a arbitrate deputes
order any o? agmurt as to wNdu yDU and d we e hive agreed to
hrbalirm dspsrtes, N you do raw send a rejection notice, you will
be 0 b6grted by the Arbitration of D'uprrtes secion with respect
o thh and arttryy prix ?aotnM you have had with w, even if you
have prm iwafy sent a rejection notice with respect to that prior
USE OF YOM ACCDUNE Your Amount may be used for
• P.srdrass - to purchase ar )eau goods or serves from
number tmg mcrthxM by presenting your Card or Account
• Cash Adwhrus • to obtain rash advances from participating
automated tiller michihm financial irathrtions r Other
btaSors, or by meam of checks which we may furnish to you,
all in a¢brdnrce with such additional terms and condrdam as
may be imposed from time to time
•Balance Tramfers-totramforbalancefromotherutd), or
to mate Other trantaction by meant of balure trander
coupon r chef; m attordance wkh such additional to
and conditions as we may offer from time to time
In iddtim4 your Accmunt may be used to guarantee reservation
at participating tM6luhmeraL You win be Rabie for
guaranteed resen atmms that art not anmled prim to the time
spedfe,d by the esubahment.
Your. Account may be used for personal, family, household and
cherhible purposes You Account may not be used to Obtain
loam to purchase, curt' or trade in seoatdes, or to arty
amount you owe under this Agretro" ('PTpayy Ahbhed
Transaction'). Prior to its tae, each Card muri be shined by the
pwum t whom B it issued. we are not m ponsdde for the
refusal Aa neon to aexpi or honor a Card or to bout cards
that
thou t prasaded you. You meat return try Card or unused
checks w upon request
d a merchant fans to provide your purchest to ymr satisfidim
and, a you request we love a credit to you AunuM you vn'B
pt r gigue u agree teeprovide us with written midem Of
30 described in the Wiling rights summary on page 17.IB and on
stover the bad: of your monthly billing statement apply Only to credit
re j card transactions. This special rule for etch card truwrtiom
rut does rat Appy to po cases made with a balance trardr dud
vent I Or cash aghvanr . Therefore, d you have a problem with the
amount due
°f AUTHOMED USERS. If you wart to cancel the authrhty Of a
^ ; {oast than TO pay amounts owed) may be emertUed by any
T { be doomed to home aligned to us your claim agaust the
u i merchant tn*or hay third putty for the credited amount. Upon
assignment.
d Your rights and respomibTties under 11ht Per Credit Billing Arc
re quarrtv of goods or serAr a that you purchased with a balance
i ir
e a r dream rash advance Check or the pDoretfs of a rash
d tdvtme,y?•OOu do not have the right to withhold payment of the
i notify is in writing or by telephone and desbop a rd'irh that
ppersonY Pouesxionu None of your rights under thh Ca Agreement
person not a Party tothh Agreement acting pursuant to a pow
i of attorney withDvt our separate written agrm ent which we
are not obligated to give).
UNAUTHDRUD USE if a Card h lost m stOler, or if you think
that sorreone is using your Amout or i Card whlh ud your
permisciOM notify is immediatev You can notify us by
tekPhOrding 1-ODD-D6CDVER f1-$DD-347.2fF3), r by vatting
DISCOVER CARD, PO Jim WS6. Wrlmingto^, DE IM;-ItML
You agree to assht rat in determining the facts relating to any
theft m pts"15le tmeudhorized use of your Arrovnt X a Card and
to comp yl with such prorsdures as we may require in conritrdon
whth our investigation. d Dur recards Sato that you have
enrolled in an automatic billing arrangement such es a mbmhy
gym mtm!>vMip, we will attempt to provide you new Account
number to that mertharn Hbwemc if you no longer with to
CDnt)hve the automatic bnrmg amnprrer% you must contact
the mertiuntdirecty.
CREDIT LMIFAVARABLE cuxc we win tdvat you of you
Account mdh limit We may impose a lower Trinit that will apply ..
to cash advances, referred to as the ash advance cede unit.
You agree not to allow you unpaid batons, incvding Finance
Charges and fees, to exceed your Accourt cede 6mt it you
exceed you Account credit limit we may request immediate
'3'
payment of the amount by which your e=rr-d yrnu Accourd
. • - credit Funk .
yVe may. or dbmwe your Account treat nrnft or pov
cash advance credit Omit without notice. The cedt milable for
yore use may, from *W- be her than yourAaount credit
For as of FimR. ptupos termbring your avaB?ble crtft we
resenmthe" • M to puaporu iw up to is business drys reducing
your unp.id larcer t>y the amount of any Payment the we
•- receive. Your avanabk credt will not be Increased by the
.. ..:. ?+ amwtst of any credit balance.
PRD"E TD PAL You agree to ry, u in US Donors for an
pundhuet cash advancer and balance transfers indudmp
applicable Finance Charges and other charges or fees, incurred
by you or anyone you ruthorbe or permh to use your Account
W a Fart( even ff you do not AD* us that other; are Laing your
Acc aura or ? lard. We vn7 wnvan purchases and cash ?dvences
made in a foreign crrenry to US Dollars at a rate misting on
the date of ronversion. N you pay ur in other than US. Dollar;
we may refuse to adept The payment or charge =checks our cost to wrwen your paymerd to US. Dolla>z An checks mum
be drarm on Undt en depose m the U.S. You may not use a cash
advance check balance transfer chock or cmporr. er anryy other I
prOlNeA nal had: drawn on any Discover link credt card I
account m make payments On your Account l
If your Aeau t b; & )*A Acwnt each Of you agrees to be sable t
individually and jpediy for the errth amount Owed on you
Amount We can accept tote ps cot or pardalpaymems or
rheas anti money orders marked etgmem in fun or with any
other restrictive endorsemvd without losing any of our right;
under ft Agreement.
•4
when tlr_re are twvo initial special rats appnmbk to your
Aanut and the tower Annual Pecentap tote win expire
before the higher Annul Percentage We.
MRitdUW MDNTHLY PAYMENT. The Nfmimum h m Due
each month win be the Win of ?ry amount pea due and the
mi=n nmfh¢ payment. The minimum monthly payment
eawink the greater of SIOM or 150th of the New
Balance, rounded to the nerd higher whole dollar amount if any
ANKIAL PERCENTAGE RATE appnmbie to your Aeourd a
greeter than 22.99!4, you minimum morithly payment win be'
greeter of S 10 or 1ldSth of the New talanm, rounded to the
next higher whole dollar amDUm. Regardless of the Annear
PtrMrIt%gp WIS en your Account, V The New Silence is its
Than S1D.K the minimum mocnhfr payment will be the amount
of the New Balance Paying the Wmum Peymerd Due may be
inwffideM to brim V" Atmum balance blow vour Actnuni
Ina v.TrlhMR Fee dtWIPed in the On:rf'mirt Fat Section We mat
from time to time aflow you to not mate a minimum mon%d
payment and win notifyyrnr wham this option It avaflablL If YON
take advamage of the offer and do not make a minimurp
monthly payment, finante charges and any appricable few win
accrue on your Account in acxnrdaret with Thu AgyttmerA and
you mtat pay the NGnimum Payment Due for the following
bitting prrio
CREDIT BALpreM we wig refund any credit balance wf Ht,
sewn btairuss days from receipt of your written request If you
do not requast a cefvnIt we win vinumatially refund credit
balances greater then S I:DD which rennin in your Atrovm after
two biifIng periods'..
MDNTHLY 9XINS STATEMENT. Unless we waive our right to do i BALANCE TRANSFERS. VA may periodmty offer you the oppoT-
so,, we will send you a bnfng statement after each monthly oinily to t»nsiv bate mar from other creditors or tin make other
biting period in wfnirh you have a debft Or credit balance n} , trensaeliorr to you Account by means of balance trarufar
S1AD or mrosL The Mn2 nalernem will show an purchaser, coupcus Or rhed:c. Each offer will contain an initial special rate,
rash adwKes, balance trandem Finance CuTgs and other which win be the Annual Percentage P.M that will apply to
charges or fed and of payments or other credits posted to you trasfened balances for the time period zpecfird in the offer.
Account during the bill mg period. It win show your New nrbjed to the Default We Mar, Section, and may contain a
Balasde, Minunum Payment Due and Payment Due Date. Balance Transfer Transaction Fee Finance Charge for each
MDNTKLY PAYMENT DIRIDNS. You may at any time pay the balance transfer made during the term of the offer as disclosed
entire New Balance shoym on your bgfing statement, but each in The Dfitr and as set forth in the Pricing Schedule, ilappnoble.
inrfened
applies { of 7h¢ time is will the annual Perrentape
After the month you mum pay at Itart the M"mimum Payment Due- All We that expiration
payment; mean be made in accordance with the tams, including bit laRatences Balance e t trans purchases sd will apply to tranate
are
the payment MAO time, stated on you monthly bilnn9 state- sfers subject arSf the initial enn eteetiat me are
merit and we will credit you account in accoTdanre with those Which The atte in rate s spacialrate bat e has Ua, a ire to to toms in addition, wee reserve the Sight it. dh"a those terms ph`i`ts e balance nte tramfers. Each off Tc or er re referred
n an
without prior nD*L 1Ne win apply ppayymments and credits to the tr1°ze rat b will contain an
New Balance shown on your current bftlrng statement in Order Of
the An" Ptrcentage We applibble to the balance of each
transaction category fit referenced in the Periodic Finance
Charges Section), from lowest to highest btoinning with the
balance subject to the IDweet Annual Percentage We. We then
apply paym:ms and credits to any new trersaGrord using the I
came method However. we have the right to apF>ly P+Nn 11
and credit to balances with higher annual Permrttagt Rates
prior to balances with lower Annual Percentage Rates, such as
-a-
tzprauon dqi d you attempt to trandet balances by meant of
a rhrd: after the expiration date. we will Tr_st the transaction as
a cash ad.•anke, We win not make balance transfer; attempted
by Marc of a coupon after the expiration date.
FINANCE CiARGK Yov tin amid payment of Periodic Finance
Charges on new purchases if yOu pay the New Balance shown on
the bTifng MTemern on which tfie purchase fun appean by the
Payment Due DaTL and the Paymhvhtt and Germ on that
statemtnt equal w exceed your Previous Balance. We otl thrt
-S-
the 'pmt pethod.' You do not have a grace period on balance
Transfers Or cash advances. Prnodhc Finance Charlies are imposed
on new balance Transfers and ash B:l", S beginning with the
_ date the tranocti= occurs.
nZODIC FINkma Oi SEL Periodic Finance now art
imposed on ag transactions until the date of repayment.
Repayment ratans payment of your, entire Raw Balance.
tlvoe It you 7 the New 8ahna shown on the current
billing rtrternent q the Parntnt Put Dint, and the Payments
and Cndts shown on this statement equal or exceed th•e
Ptevioett Balance, we wig not impose Periodic Finance Charges
on new pzxch s, that 4 purduss first appearing on the
current statement Dtherwsce, you will receive a bitfcny
Ybtement the next month that includes Periodhr Finance
Qarges imposed onto the date of repayment
we romps" Prnovhc Finante than u each a.
cash advanctt, and balenre, tlo art (which
troruattion cafeppones) by using the folio
Avenge D%)if Balance s number of days in thl
Dagy Perin c We. (You may refer to the
tunuaaq vat the front of your bifgnyy rate
amowliJ Thew we add ag the Periodic Finance
ttansactfoa uugory To get the oral Periodic
for your Account The Avenge Daily Balance IS
no Periods: Finance Charges apply to the balance
Wtpvril
3
for purchases,
T refer to as
shown as
in a trap
We use the two-rydt avenge daily balance linduding new
trensa66ord7 method of alwfaimq The balance upon which hw
impose Periodst Finance Charpec This means hf you did not pas
the New Balance shown on The beginyD statement you racer,
during the previous bilfmp period by the Payment Due Date. we
wig impose Perivec Finance Charges on new purchases That first
appeared on that bidinp rtinement.as well u new purchases
tut fast appear on the arrserd billing statement unless we
already imposed Periodic Finance Charges on the purchases on
yvw prrvhput bilgny ttattmtnt We compute the ovens daily
balance fur each tnhsarTOn category by adding up of the deity
balarces In a billing period for a transaction Category and
dwidmg the total by the number of days in to billing cycle. We
compute the daily balance for each Transaction category on each
day by fast adding the following to the previous day's daily
balor,= transaction; made that day, fes charged that day and
Periodic Finance Charges accrued on the previous day's daily
balaw and by than subtracting any credits and payments that
are ap?pf(e'd against the balance of the Transaction wegory on
thin diy.)n calculating the daily balance for the pre«ioui tilling
period we consider the 'prtvious day's deify balance' to have
been fro on the fiat day of the binning period.
Special rate balance transfers and Balance Trarafer 7aiuadfon
Fee finance Charger tee included in the daily balance of the
balance tmsitr tnnsacaDn category galanre transfers that
were sybjed to an inlibt special rate That has been terminated
due To a late payment or because your outstanding Account
balance exceeded your Account Cledd Unth ere else included in
this category hmfg the initial special rate otherwise would have
-r-
exptted. In calculating The deny balance of the balance trarufer
fianattion category on the first dry of the billing period, we
subtract the unpaid balance of thou Balance Transfer
Transaction Fee Finance Charges and balance transfer; that
become purchase rate balance transfers on that day And wr add.
that unpaid balance to The balance of the purchase trtmanion
ateggxy.
All fees charged to your Account art added to the purchase
tn"rhon category wfth the exception of Cash Advance
Transaction Fee Finance Charges which are added to the ash
advance transaction ategory and Balance Transfer Tnnsacu'on
Pee France Charges w£ndh are added to the balance tramftr
traraatzion ategor? d a tnmartion Is posted to,yoa Account
after the dose of the bimhp period in which h occurs, we wig
treat the transaction as having occurred on the first day of the
b'Amg period in which B is ported To your Account
ft) Pate plans
The Deny Periodic Rate and corresponding Annual Percentage
Rate that apply to each transaction otepory is either a foed rate
or a variable rate as set forth in your Pricing Schtdu)r. The Daily
1 Periodic late is tl35Sth Of the corresponding Annual Percentage
Rine_ The voriible Annual Perceraapt Pate for ? Transaction
ateyory is determined by adding a specified number of
ppeerrctentopt points U the Prime.Ratt. This IS shown on the Pricing
Sdheduk as 'Prime F (ptrctrrnye Pound.' For purposes of disc
Agrtnrtent the Print Rate is the highest me of interest fated
as tit 'prima rate' in the money rates section of The MRStrrrt
Journal on the lest bmintsc day of the month. The Prime hate is
merely a pricing index and does not reprvers the lowest or best
interact raft avatlabit to a borrower at any, }xnt at ;ny given
trims. Your Annual Percentage kale win Increase ar decrease
when the Prime Rafe changes. This change will be effective
beginning on The fra day of the bilgnQ period that begins
during the same momh as the lunge in Prime Rate.
(2) Annual Percentage Rate for Purchases
We may have offertd)ou an Introductory rite on purchases. The
irmoductoty rate IS The Annual Percernapa hate that wig apply
m purchases for the time peirvdspe?ed fn the vMrr. subjKl-to
the Defeuh Rate Plan Stction. After exp'nraTon of this Ome
period, The Annual Prrtrnage Rate for purchases will apply. The
Dailyy Periods notes and corresponding Annual Percentage Rata
in eifeR an the dolt this Agreement ¢ fvmuhtd to you are sat
forth in the Pricing Sd,edul_
D) Annual Percentage Pale for rash Advance
The Daily Perivdh[ Rate and corresponding Annual Percentage
Batt in eifed on the date of this Agreement is furnished to you
are set forth in the Pricing Schedule.
(4) Annua) Percentage Rate for Balance Transfers
The Daily Periodic Pate and cntrerponding Annual PerctrUcit.
Bate in Na for special rate balance Transfers will be set forth
in The offer from is under which you make The balance transftr.
As indicated in the Balance Transfers Section above, purchwe
-7-
rate balance transfers w49 be subject to the Daily Parodc I
and corresponding Annual Percentage Rate that apply
pudaus and the Default Rate Plan Section.
The Daly PeriDd¢ Rate and corrnpondohg Annual Perterr,
Pate in effecl on the date the Agreement is furs isFved to you
set forth in the Pricing Schedule.
DEFALXT RATE PL AK We wig review your AccmM on the
day of each Milling ptrnd to determine the Annual Percent
Rater that will apply to your Amount In reviewing your Aran
we wig lvtk At the current billing period As well u the prevh
eleven 6MM ptriodt. Any increased rate described below h
aeoly bWeinina with the firA day of the b71'mo Deriod in wh
balmym transfer that we have previously offered tD
16du6oN if fie standard Annual Peranhge Rite for pu
it lea than 19.99% and during the immedately pre
el&nn billing periods we did not receive a required ptym
the A nt Dirt Date, then- the Standard AI
PERCENTAGE RATE for purchases will be increased to 79J
Daily Periodic Rare of Mtm%1.
D MMUnd ing balamt e;arsk your Aunt uedd i
of 1* car We review your Account and yosr au=
balance ="tied your Account credit limit at of the last
any billuhg period in the immedately precedng eleven
Periods, triter arty inhW special rate on balance transfers by
htrndvabry D; promotional rate on Purchases that cur
ipplits to your Amount and. any rush me that we
nerviou sly Dffered to you will terminate and the sta.
Annual Percentage Rate for pwd,asn wig apply to the bs
A your balance tmnFftn and purchases At well as
ntrodi" or prurnmicoal rate Day purchases and any
Decal rite on tAlamr tremftn that we have oreviosniv of
3% of the amount of each new vhsh advance. There is a
minmum Cash Advance Tantanicm Fee FKANCE r-"'GE of
15.111) and no mas)mum Cash Advance Transaction Fee FINANCE
D;ARGE,- The imposttfon of Cub Advance Transaction Fee
Fnaryce Charges may rerun in an Annual Percerage Rate for
ash advances that is higher than the nominal Annual
Percentage Rate. All fours of aA advances, indudmg the use of
Discover Cud dyed , regardless of the'purpme for which used
am;ubien to Cash Advance Transaction Fee Finance Charms To
obtain the total Finance charge on ash advances fDS each
billing period, KT Add Wry Cash Advance 7rerimtiDn Fee Firance
advance tranwcdw, category.
ACTON FEE ANAN1E Cl-"GE5. If
you receive contains a 9alance
mce Charge. we will charge you A
Fee Finance Charge for the amount
DreADWy offered to you, will tamhinate and the vandard; of each balance transfer made under that affes d there is ?
Arv Percan'4ye Rate fur purdases will apply to your balance 9blame Tranrfar 7ramaetion Fee Finanue Charge )n conjunction
of balance tratr; and purchases a well At any irsrodurtory or' with the offer you received when you applied tw an Amount it
rMotional rate on purchaser and any initial special rate on Will be in the amount set forth in the Pricing Sdhtdult. The
if we did not receive a required payment by the Payment Due
Date during the Wimp period in whic h we rrview your AccDynt,
then any initial ;pedal rate on balance transfers and 'any
intyodu[ts rf or promotional rate on purchases that currently
applies to your Ammiall, and any svch rate chat we have
purchnes wit be herraxed to Ice :9% fa Daily Periodic Rai
.DSAT7%).
if your sandard ANNUAL PERCENTAGE RATE for purthan Is
than 2439% and during the anent and immediately preen
tkven 5111mg per)Dds you either failed three times to =1
re iced palm ent when due or exceeded your Account a
Omit three Times as of the last day of a bilingy period, then
standard ANWAL PERCENTAGE PLATE for purchaser and for t
advances Will be increased to 24.49% )a Daily Periods Rats
.D6642%k
WH ADVANCE TRANSACTION FEE FINANCE OWGES. We h
charge you a Cash Advance Transaction Fee Finance Charge
N! imposition of 9slanct Trarear Traraction Fee Finance Charges
ter t may result in an Ansuai Percentage Rate for baance transfer;
no: that is hightr than the nomnal Annual PerctnUpt Ram To
by, obtain the Bola) Finance Charge on balance Itareen for each
AL billing period. we add any Balance Transfer Transaction Fee
ja Finana [herpes calculated under the Periodic Finance Charges
section for the balance trareas trambElion category.
A; MIUMUM FINANCE OiARGE. We will darge you a minimum
I FINANCE DWGE of 1.50 for any billing period in which tome
Df I IFIWAMCE CHARGE of less than 1.50 would otherwise be impo;ed.
'D RETURNED Ca%CX FEE We wig dharpe you a Retuned Check Fee
of 129.DD each time yyooV For sal with a cauk that , retvmed
?' uthpascl. This fee will alro Epp d a debit tnwction U a deposit
d account from which you wt authorized us in writing,
electranIUDy or orallyto perioditaDy deduct at or a part of in
t
amount you Dux in under thhs Agreement is returned unpaid.
we wit charge yDD the fee the felt time any payment s
f
returned unpaid, even If It 4 paid upon Tewbmisuon,
s RETURNED DISCOVER CARD MEa FEE. We w9'g charge you a
r Returned Orctk Fee of 129.DD each time we decline to honor a
r Discover Card crA advance check batarce tranrfrr check or
other promotional dark.
STOP PArMFNT FEE We miry charge a Stop Payment Fee M
$IS.DD each Jima we stop -payment at you regent on a ash
advance dhrck, balance transfer dud; W oth,c promotional
deck
IATUM We will tharpe you a Lite Fee if you have failed, is of
the PLvinenl Due Date, to make the bfinimum Payment Due that
was re ifed to be paid by that dote. The amount of the Late
Fee it owed on the sum of on c,,wxndng pvrdaa; ash
advante; balance transfers, other tfurgn, other fees and
Finance Charges of the tnd of the bi)tng period. If the sum b lea
-3-
.... .. J'Y.
than S IM The Late Fee it $ IS. N the sum it =pal= or great
Than $t DD, and Irk than S IXD, The Lots Fit Is SZS. K the sum
equal to or greater than S1,0DD, the Lett Fee •s 333,
PAY IMMIDNE FEE We may from time to time allow you t
make paymero by authorising us over the Telephone w transit
or pay fundt from a dtpodt account to your Amount We wi
charge a F•sy-by-PhDne Fee of SIP for each rude transfer a
paymmit
RESEARCH FEL Wr may darge you a Rstarch Fee of SS.DD fo
Bath copy of a Mil statemerrt or ales rrrp that you rquesi
HDw•evey we will not urge a fee if you request copies it
ronneaion with a billing error.
DVERIJMIT RL We will tutee M an Dvedrmit Fee each time
That of of the dose of a billing period, your Dtmtandaw
Auaurd balance weeds your Amount credal Emit This fee may
be charged even If the t imsartion which rotas you to esxeed
your A¢Dunt Cedd molt It authorised by ca W K yDU exceed
your Aawm tredh remit due to the posting of Financq Otarps
m' its To your Amount Ttu amount of tha Dverrr* 1te e
based to the rum of an ouUtphdeng purchases, cash adoncet„
The Dverfimlt Fee It STS. K the sum -s grrater
the Dvarrunh Fee Is S3S.
TACCEU&MON{DUECftON COSTS. You are in de
ecomt hsDHent if you file a banbuMe pet:?ion r
S againtt yob if we hive a reesorubBef t ID,
x uenvitrmg to repay your obligatiors to us; K ym
f incompewat by a coot or if a court ippor
for you or a cpes"im for you asset; K you d
taNng to make a required payment when aloe, exceeding y
Attmal credit Bmlt or using your Card or Account fo
PrDhibltrd Tnnurtfon. K you Art m defiuk we may dedare
entire balance of your Aammt immediately dve and pep
,without notice- K we refer the mliection of your Amo rd to
ammey or employ in anomry to represent us with regard
recovery of money that you owe u; we may Burge i
reasonable attimeyt lea and court or other mRection Lass
pelmi d by law and u aRUany insured by cat We may de.
enfarrrrso or not inform any of ow rights under the Agrrxme
widwtm TDSIng or wafering arty of them
CANCEL AT IM You may cancel your Amount by notifying is
writing or by telephone and rttvmingg or dertroying rw..ry Cs
and tm ned check that wt hue prwmi your. Df course, you w
Sul be responsible to pay any amount you owe ca accwcring
the terms of this Agreement K your Account it r joint Acmur
each of your may camel your Account We may cancel or suspen
your Astourrt at any time without notim We may choose not t
renewyocar A¢DUnt (beyond the acpiratian date Shown on th
fart oral a ung wizhm notices -
PRIYACY. We respte The privacy of information about you am
your Atmur2 Dur Privacy Polrry indudts a-summary of thi
ptnonat WDrrnstlm We mnem when h may be shared wed
- tb-
how we safeguard the cor6dw7tnrrry and.smurhy of
tion and the steer you may take to limit our sharing of
rte your Cardnramlxs Agreemem As inTe" iii our Prmry
d Polley, we may report to vedrt reporting agendas and other
r mdrtors t!e natsrs and payment history of your Acm^
II caseat negathe credit information. we normal U" port to
r ing'
smuin stdd rz, Etc agencies each montlL if you .that
Dur report of your Amount statur It inacnuste or incamptete,
pkse write to at the #ollowinyy addreitc Di;mw Card, PO Bor
t537B, Wilunington DE 79BSDWIL Reese include your name,
addrea, home ielephore number and AMMrd number
We may from Time To time review your craft emplaymanf and
income rtrorck Our persarmtl may Win to or record Telephone
a0s between you And ow representatives in order to m1uate
The quality of our servim to our Cardrrembers without nolitt To
you. We may use any medium including bus net limited to met
true telephone call; automated telephone equipment
prerecorded talepbone "ath, and a-mal to mntatt you about
your Amount or offer you products or services that may be of
vrfve tit you. d u grater not to be wntacted in one or mot of
these way; 0 6 us at t-BD0.225-SM or write To us at D'a:mves
Grol, P.D. Box 3D951, Suit take Citf. VT 9413D-Mi. We NvAdt
varioa methods by which you can obtain informitim rbart
your Accourn. V+4 VAR only ntease suth information to you, any
Authorised User that our rerords Indicate is ¦n authorized buyer
on your Account and any other person with your prior
ptrMiWw; in addudOn to a provided m our Privacy Policy or as
cat required by IaMC our security meatuses unrrol insure against
re vrhavthorized inquiries You agree that we win not be
a responsible for the release of information to anyone who, even
or if whhrvt your sutihDrizatiDn or permission, has gained
v poaersim of a Caid a has learned other identifying
9i dsaraltrirss about yyoou such a your personal wentifcation
a' number. Atmunt number or social security rrumbtr.
k ELECTRONIC COMMUNICA.TiDNS. We may Dffm you the
n Opportunity to receive certain notices from M tletironrally
other than through The mail, induding unandtly .billing
° stetemtnn'and change of terms notices. The terms and
mndniors for receiving these eiecte nic communication win be
d-saibed in the Offac
MEDR AUTHORQATIDNS. Certain •oarsatti= roil require our
authDAz6on prior to completion of The Traraaeti°n in some
sae; you may be asked to prowtde IdenriftatlDn n our
¦udhonution system is not working, we may not be able to
authorize a tretsartbm We will not be liable to yDu •d any of
these events happen
CHANGE OF TERMS. We may change any Term M part of this
Agretmtm inducing any franca charge rate, tee M method of
mmputinq any batanca upon which the fmnante charge rare is
.,
aaessed, w add any new Term rte to the Agreement by •,
sendrry you a written a elv= is y° dell"red notice at kit
Is days before the rhange it to become effective Wq may apply
ary suds change to sits outstanding Whhu of your A==t oo
'the effective date of the change and To new dhrrgs made afttr
-IT-
flat date. if you do,
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' - ' in willing or dean
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: iha-notka of Chung
ChWVA, in Which CIO
-
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-' pay its the balance 1
_
- -:'•t=rh..•
'i the unchimpW Agri
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! the dnah,gis in thi
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aft O
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-•i' new Tema AS of n
notified is that you
`:'?'trs: ^•'*Tt-Tf•f MANGE OF ADRRE
rif)roia nei
•
;; ? t l;' ASSIGNMEIM ACl
- ?*?? oP any Ifwti
(if oar"sw.es3 NetI[
• Our prior wrdten?oli
ARSITRAMDN OF DISPUTES- In the event of any part, preserrt or
future claim or depute (whether home upon Contract tort
313UUk Common lasv Of equity) b9hVetn you And M arising from
or relating to yyoosvt Account any prim acrCurl you have had with
s4 ydur aPP=k3t n, the relationships which rtsuR from your
Account or The enforceability or xope of this arbitration
prDviumt of the Agreement m of any prim agreemem- you or
we mar rtM to resolve the Claim m depute by binding
arfaitTabop
F EITHER YOU OR WE ELECT ARBITRATION, NEITHER YOU NDR
WE PWI HAVE THE Rlfeh'T TDIITTGATE.TK& C-431A JNLDURT
DR TO HAVE A JURY 7RIAL`DN TRAT CTA)k 'PRE-HEARING
DISCOVERY RIGHTS AND PDS'f HEARING APPEAL RIGHTS MU
If IJMRED. NEITHER YOU NOR WE SHALL BE ENTT77 fD TO )DIN
DR CDNSDUDATE CLAIMS 1N ARBITRATION BY OR AGAINST
OTHER CARDMEMBERS WtiH RESPECT TO OTHER ACCDVNTS,
OR ARBITPZE ANY CLAIMS ASA REFRESENTATra CR MEMBER
OF A CLASS OR IN A PRIVATE ATTDRNEY GENERAL CAPAOTY.
Even R an parties have opted to f6gate a dnim in Court you m
wr may eject Arbitration with respect tawny claim muds by a
nLw Party or any new daims We anesTtd in that lawsuit; and
is nothmg undertaken therdn shall' constitute a waiver OfAny
. rights undu ft arbitration prtr icion : ax.i•:,•" .....-, :'; o-
We nAl not invoke our eight to arbitrate anincmdubl clairri yoU
j. bring in small dolms court oyour nite'i egiehvaTmtr'Diird;-ifany',
1 So )c, ? AT the dalm kpending only_inxhat rDDC anduioer'nm
r c¢ted SS;DDD.Ir4-' _ d
in
BD6352.52M'w W-ist P.D:•Box 044 t, MinneapDla; MN SSADS
(phone T-BDDi74237d)•''F•tfyour'writtefi=:regLestr. we: will
advance any arbiVation filing; admin'rnrative and hearing fees
r2_
Miidn you t
as a result p
requests to
The
for
rmro, m nearmg feet in an
Dig Combined court Ccra
it rtsDh ed in a net Court
vrmicaw [bon. In no emni
or torts inosrred by is in r
h„vhunahS vecaomwur De Hoar Via orvng except Tor any
MPP^-al right under the FAA and except that if the Amount in
corfiDVersyy nardc SiDD,DDD.DD, astir. party may Appeal the
award within 30 days to a three-arbitrator parr) which shall
Tevmw the ?ward de ndvo. The cosh of such an appeal shall be
bOrre by the app[arng party regardless of Dumome. Judgment
vMj) any award by the arbihator may be enforced in Any court
Dur right and obligations under this arbitration provuian shall
inure to the bench Of nod be binding upon our parersi Corpo-
ratiwa, rubs'PATIes, affiliates finduding, without limitation,
Discover Financial Servtcm )nc), yredetessors,-su¢enor:,
ass. rat is weg As the Officers, dirtdors and employees Ed each
of ere entities, and will also invre to the benefit of any Third
party named as a CO-defendant with is Or with any of ti,t
foregoing in a da'ah which "s subject to this Arbitration provision.
Your rights and cNigaticns under ft arbitration provision shah
inure to the benefit Of and he bindng upon all persons
Contractually Rable -under this Agreement and ail Authorized
Users Of the Auaunt• This arbitation pro,$iOn sha8•iurvwe
terniinition Of your Atwunf ei'we8 As valudtar'y paymeirt jr ful
4 yDq fPyrlegfi'prO¢eedingc by is totollect a delft ihved W
r v, any.banErirpiry by you and any'tale'5yci efyo'ur-4wunf-
fnmitatiDns, YDa will hat be requimd to yep rnance Chargei'Dr
Dtiher* fiirgei: it 'a tale Ait%s :OfEater"Th'ai -ait'fiaW15ri 4?
arnount permitted by lase. if h is ever finally deftrminW ihat
but forth's Stetim The Finnnte Charges or urthrr ch5rprrunder
This Agreement wauid exceed the maximum lawful arhaurii. the
Finanrr Charges and other charges•V68 be uedured toeihe
mazimum -lawful Amauht Any excess amount that you bn,m
already paid Will be wad to redvrethe avirtand{rag Ealanrt of
ymr A¢DVM.m will be nfvnded tO)rou Ly meprspi a rherk in.
our daaetiDn., .
GOVERNING LAW This-Agmement wig be goremlrd by the 4ZAT
of The State of Delaware and applicable federal lawLd any pan
-h3-
.-./gam it-u?iy j•T "1;
? `.
-.i
I
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. our Iri
.
?iDtt?q??6-?D prPAL- yD11. •:•Wtt L
of d,s Agreement bxoms tsm•erdorttni?ir+f•. wglTaQ makteny.
ofhF'i pert wenfos bwa. .. .. '
... `bISC.CVER CABD :::? -n-r`F
• Wt;iCG' ELS'?CISF.'Pf?'.a "-'t`E.+'?*,:•r-n ,? 15
a.,.. }tp[flp arq. 'Blrfd•
rer3cet, ,y vVitfi, t)hi ,PC??e • W lifmid, ?iay you'
primary s;tome We uindimuriii your concernsfbaovanp . about guardu,p
i2mv.,tfon about you end yota Aawnt We want to zauaa you
that we fusee taken sttpp?? and will mrtinue to take steps, to
safeguard theTinfornutioFL
7bb i rh ct Porky'dscibes our effaces to meet thse bbjertiveL
K induds a summary of the following important infs.rmatiore
• A ruling of the prsswid information we collect
• The cirtImateres A which we may;hwt infbrmation wrih `
othem
• The ways wt safeguard the amfidrntinlitp and security of 1
Information ] ••; ter. _: p5..^. '...q
• The Reps you my take. to •rimk?duf :sbaficp 'of::sisth
womwTibn WM othtm See Section t for complete detak
Menu read our Privacy Pal orefullX it will help you undu-
mnd how we collect and akart Information.
I. MWI Personal lnfonmtion Do We wits?
To sae you better and managt rata busing it is important that
wx collect and mairaafn Accurate personal jnfornalion about
yyoouu We Dbuin the sifwm stfen from apprrcttiont and other
fbarra you submit to A from your dealings with us and ether;,
from;v=merrepoltshp agaat M and ftgm othersbures,•'stsch
"'Pur tb etaL for-!-?m It_. • l-;.1 •?3 •i'. •?.f:
•,we-rntyewvta?tn••mmmavon.fcrr;;:.s ?tpupk atiancesr
pnymtld s,; ?•..?..?A: your Ur4 Vf-ymla l..s;pssr!} irid the type; D?
service you prefer from youramactiort and other dealings
,vvitfh.uc ind otherh;;,__:•,.-;.`zs:; ;.v t'. +. .+
t.thssyy olYain infofdlktioq tuckatrhp 6aiancer cdyourlbini
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with l er- eh anzand, ur paymert Khrroty ivFdr `ut3ier irorrr '
tone,rmxiepa^?Ny.aQGiipo's.1• • ? .'.--•r ;:.?+:::
1'de' rhay tobiitn irhf'ortnetiorru +?d, h; ii: ypGc' Iriir7nef •sGrvice ,
provide; your domsiirs riame•, yctir. cpmpvtefY: ;optFltifig.•
' syttun end Web brmvseCyoutiAteb sfte:arse andyourprbdvct
no tenfce preferenm fiom your vafa a but Web sites.. : •.
s.`-'rt'e C,:-_ k-_-?J
L is Petsonaidrdormatiod Shsr-d.tYrth
W; WyK ;hiring o'f mformsinri'N
wig freate a On of Cardmembers syhb. may I>e
offer based pn wulri urit:i:dstia: N'r M
a
understfrid'thaCd jtgp`de;ia2fda'ms igpl;of bffet from-is end
thb,bt to'iike'ai3viniige o?ic11-;r reuifer mat' diet aetni
information about you i>vmust only Cardmember wish tirtbirn
chanrtwislia received the Pifer,
Thee are, however, riramut%nces in which we may share the
infar"don we wiled sbovi ywy as dsm'btd in Section 1, with
Other companies n wder to provide you with access to pmdum
and services ar,d to Wvite you Accourt effectively, at Crta6ed
btbvt We require them companies to adhere to out. priwry
Ranched; and to use this information only for ihe'rmited
purpwe for which It was shared. ;We do not allow.tJrm to
dsdore It to bthtn vridrovy.bia pri?r:ipproval, _ ,.y n „-
i. Sharing Ptrsbnip in 6Katiofr vrfih-7>ra'• fWpbrdle: 4m, ilJ
We are' parl d the Morgan Stahley family of wnipanirL. Dar
corporate family offer a wide vanety of products and seivifes
that an help you manage your fi ames. M wdn m provide you
with am= to these product end service:, we map share the
information we mgec about you, as daarrfbrd in Section t, widh
and arset'-'
;emti prahddtrritt#Ift%fr7turetuaris m7pdratKdamily icntinued
to grDuct%'}'1
_..AiirtctiriyPv,9o€e{:.,.; IF . .:_ .,...,._ ...- rrir•.t . ? .;: ..
_4-
We may;hare tke.,informatioo- wr cbliert about you„ rt
described in. Secton.% with nbn•affiiGsted third parties,
Including that that aaept the D"k er Card,. iri,arder, to
provide yoy with Mea to produt'a and sakes offered directty
by these rbmpanies that may be• of valve. tb yeLuJlk ae
companies indude financial service pimiders, such as insurance
cotnpaoier, ihd•norOitlnriil tbmpanle.4 such as reta"ti - •`" -
e Sharing Personal rnfwmaiinn with 4rhen .. ,
We may"share'the'informatiba'.we collect about you, ix
described in Section t, with companies that psrfordh support or
marketing unites bra our behalf, svrSh as mailing, market
. - ts -
yf
resexrh and dati'pcoce:ssin :vd>s. nendaL-;ncTftufl5nr'vrr,It
which ore have joint rriAetsng agreemerttc or. mmysDips that
are Die partners for mbrinel?,Credit card 'prvyra?s,; or>ihvard
pragraox. lM1k Inry aso'share, sudi ipTorciagon-as perfn}tted 5y
lavhi .:.: .
3."How' Da' We Pmtpcfahe Cnnfidanttatrty, 5a rfy And
artegtj Df lnfbnrution Abavt rout r ; . r ......
Wt maintain 07061C Oic op I and, pt?mQuraT ale`gvaa.tD
R g mportant that the information WE msurtain abDvt you s
acmm* and complete. d you sue ftrformaiion in your monthir
billing statements or eisrv/we which suggests that our
information is iruomplete nY ir0mrsta, please write to to at
Discord Card, Y.O. bas 36943. Salt Lake O y, to 64536-0948 so
that we can'updau [Yhb information.
0 How Can You Umh Sharing Of mforraaSon About You?
we rrSpeR ynvr prh*cy and offetYod-chpicei as t6 whether we
mq lure mfonru4on about yonw@7ieithii a:p-faFihit
%'t rat share tM irrformadon wetolla , abovtybul u drlrr5bed
in Section 5, with nan-sffifisttd ri' par6m or if you prefir titer
we slot share that information irilfr Etmpinres in our corplirate
famNI you may opt met, that s, you may Bred us not to are
that infwmiton. If you indicate a preference tluI wb do not
share that infDrmatiorb please understand that you will not
retelve offers for'prodm a and sees ,provided,_by,. gther
farripanin that rdi/Yd help you. lowrt gbLr.:cdstf., tndi 1m ze"ycur Y. L finandalraDurtes rid mmuge ?ayda vfirjantevt' •.r
7o indiv>r R'Dor preference??$'asr"at-t8D422S$20i m wrlfe
iD cat at Discover Lard; PD. Sda 369C?Saltizke.[ty;-)1{ 61736[
0967. if rou, have DrtviovrJy ratified ru:abohrt.Wur privacy
'cA
a
a yoJr rerijnt; wit require that the fn ionvoe pr
"raid nMp thravgh i ftr3-pirfj You will ti
us wftlrjtitdrefrreric?7ol;Fain"isedit;rar3'a
rwhH car • .-.'. ` : P. .._ . -_....
c. will hono youf request ins{ inet4u
about you, erreptas pennttted by-
permns car to share infmmvy)Dn
reporting agnrems. service prmde
-is-
r r+
awl-For esa'mpirlederpl law
abort ypv°y%ttlftcapwmet
r and marketingpacfrhe2 h
.•l:•
also.p:tmi{t;er#'o ikktr•?firrmatimr-n5out:evc.:,.pcritiiru gad
trarsaa5orjiAgtl, you; rush as -fvw. Acraunt' balance' and
paybrent'hiaN with other member of our mrpf awe famh7y. if
Wet ere a rgtec{3rdmembtG we Will not share arrrjitiolma-;mn
about you, t=;* is permitted by lawt for thirty 'days liter we
prDftcli this PcRy to,vciur in ordar.vo give you an pppwtmhy to
'vdofm or obdvt' your preferences. H you are an ixdnin?
eardmimbe4 please tmdeurtahd'thit you may continue to
receive markem+g Offers 6mctir from orir_r companies that
wem already "ia prodvrtiao prior to the promming ct your
?'C'.: ',--?i ,rfl::!'::aisd dRt: vrE ..
fits RiJary.Ppfiry'.jcp'rgrufedtithe.primccy,'Caridmefnbviafed
m theA. 1•latyeyty_anyjPlrff Care mvrber hn the right to
zbodl fbrmei nstriroer? nii: `h peitnrtted by law. • .
This Prhary Policy $ provided to you by Discover Bank and its
subddsariM whkh currently induce GTC insurance Agency, int.
R ?pprom to the Discover Platinum D'scoves Gald, vacs wr
Classk Discover Private Imse-, D'acover Trtanium Card; and the
products and services offefed in munerttpn wrih those cards,
including The Register` card registration service (with the
exception of ary information rcrcp1aved in mnnecdon with the
service, which YAK not be;harecM R s part of your Cardrrhemb-
Agreenxrt and prpvidjs_a fVrther erpltnetiQn of how we
collect and sharp infAunation?(eu?riay.•haye,? el,r+g?iu.ngdu
sta{t laws that apply to whit infarmstina,-Pleasrt nok?t5at'yor
will also receive privacy no res for' pthir reds card accounts
you have widh us, as well r ocher Snardal products and strvi m
provided to you by sic and our affifistac You will need tD
indlime your preferences for each of these stparateiy es
darbsed 'or the notice.
Vemswrf and Nerds Dakota Residerrts- Yow State laws require
financial insti%gions to obtai4 your xDment prior, to daring
information about yeu.whb ethers. Except r pt mHed 64
we Will not chart inivurtagiamwe .EO.BeCEtebovtysiu withh n?ie
a`fiGsted third partiet.uQj.yDU nrl„t:Yerm6rii resident Y. nth
mmAinles.in bur,ccipbrAe fat 4j'sI?rJefi`'bu"a71'm at f-_BD6
DWDVER and' trthpriit";Sa',td do set. -"'W '. ,
fir: .z :..: .,, t?:*: .. .i fi:•. ;?A
2.v =nrra ad' 1'?w
Your,$ijI ng Rigfits.,;: ,
KEEP THS -NOTICE FD.R FUTIjRE U5E`
WS notice contains imPa4iarrf•ietormaliDT aboit-yDUrt Hg'htr-
andour respomfbTitta under the Fair Credit 9fliinSFACC•- •' W :.
o .,
f. hbtify fJ1 in Case of for' w Qiieitionr,Aberit ydrrrBi?, ...
d you think yDIV bill s wrong: or if pv nttd more infbnhrtipn
about a transaction on your bin wrhe sic on a separate nctit of
StF ?-;'? - ? ? - ?R
t` j Fit
tfi re....-.
peps ak'dre:eddrns'la'?d-onyauf; bilLfm• NDticerof 1176;;,
Fjrora vmtm td us:at tobaret Possible. W&'mud heir fiom you
no 6if=rr4han 60 days after wr entyou ibi flint W-on which the
error'w problem appeared. Yoy?c;an t:lrphone is, but doing so
wtll cot prrsrrha your r3ghtt • h •_?: y , . %1, •.. ":D
In Y?+a (.•1tr49fae.ta c?f foyllor+n?„p'ahi%a`nFtiore_`?
?...
• yvUr name and ACmtird ;ttumSeL" _. - „
• yoga dollar amount bf the suspected &t4. • desvibe the error and exniam. if you un: ivhi,ki believe
If
the automatic payment is scheduled to Dcrm
L Your Rightr and Dur Rap0nrWilds At. 'r We Rem,e Your
WrMea Notice
We and attnWAedge your letter within 3D day; unless we have
tonected The error by thesn.WrNn 90 day; we must e)ihn
corned the error or explain why we believe the big was correct
Aftu" receive your lettet we cannot try tD cDDest any amount
you question or report you a dernquert. We cask rDmbsve to
big you for the amount you pumtlarg ihBcduip %Knfe dhirges,
and -wena Apply troy uFfpJiir onfoim`t'apiiiut<yo(tr,ACcmurd
credit WC You do not hrvy to-yap any. quettionEd amount
while we ire Urvestigning, but you arc still obligated to pay the
parts d your b l) that are not in quratSmi
if w•e fated that w+e made a mistake on your bit you wnl not have
tD pay any finanrs charges related to any querlivnid amount If
we didn't make a mistake, you may have to pa the finance
chugit= and you wig have tit make't)p any m.sed piymerits on
the gsestionrd amount In•either =use, .•ae wig tend you a
nattmant of the-amount-you wore and the date shdt$a dv_
>• kr..r_:?hit-.. .••
I?youi n fai.pay li'h Ymtrwrt ti,a}14.r' rnt, 0w4.' :,May
seportyvu' a etnnpuerit'Aowrve4';f.'vuc:tselaniligd ilDei'APT
iat8fyyDOandyouwriteui:ivithehten'd'tifin isi)iatjod
stiff Rh6A to•pay, we niu+lf ten ah•sj•Dnc we report youln -t
yew
Pilot ahques5oh ibout g-bij., HL M. ivp mart ten ya 6 soli nema
of anyone .ore itportrd yDU Tiff We must teR anybne we 'h
you to that the matku hzs beefi settled between Is tn it
Finally h d we don4 fondi%r t}ieie Nit; s4i cant coTlett the first
isD of d¢ gvrstlone .1moeven ifyom bill wet m_nect •
L SpeW Rule For E edrr Card. Punfiases
you
in
ndlto•yay the.rarnaWny arrcaurt due hn the-goods or services
There are two limitations on iho right.: - • - s
_it_
AMIN
40
faliiou: deMhtyurrhese in your home este-os, if
nm'-Wrthisyeon home rate.. within ID0 mils of your t»rrtnt
mamirf:lddhesti and
(.60 hi psird:ase prl--a must have been more than $50.
These fmlfstiona do not Apply if we b" or operate the
matchaot, or if we marled you the advtrtutment forthe goods
orstn^r••
DISCOVER' CARD
CASHBACK BON'US':?ROGR4M'
TERNS ANDJCOhN{ riIONS
The Cnhback. 6onvs' Terms and Condition mttsthvte a
separate and independent aprenmeni from stet eardmember
Apnemant and apply to Accounts that participate us the
C.ihbsdc bores Progtxn Ho yrn-4 these Tema and Conditions -
are subject to the Asbhration of Disputes section of the CArd•
member Agreement which is intnrpDraud hereon
I. Ceshback Sonia Awards are smourtts denominated in dollars.
and term which may be scored by efrdmrmbers by using their
i D'racorer• Card for quaRred purshauz Ceahbxt Sonia Awards
t induda Tractional Cashbidc Bonus awards And ether Cahbett
{ Sono Awards as deacribed belevc, Caihbark Bonus awards are
not a=wed for Profdbfted Traruactions.Ia defined in The Card•
member Agreementl,=ash aammei cr balance transfers:
2 Traditional Cishback Bona amounts are calculated based on
purdwes made during an annual period corresponding to the
Cerdmembers aroh)versary year AS dessr3rd in paragraph 3
bebvs The fort mnh errary year begin on the date the Cud's
issued and ends on clx IRA day of the tw•efth monthly billing
period which fotlom Each soacnive anniversaryyear it the
0PPoismate one-year period comprised of the next twelve
monthly Wimp psiodc,
3. Erupt as provided 1>0mv and in paragraph a. below, the
accutd amv r of i-Traditional Cashfiatb Swim award u
cakuUtrd by muhiplying the t%W gvalifed purchess at the
end of each billing period by. - : r • ••
• 15% 1-MM, if the purcham are pan of the Sf,500 in
purchases during The Anniversary year, or, 9 Thvpuipdhein are
made at select warth0me dubs or c4cmim stores, and
3091 (=P), if the purchasn are part of the sb6"J1,SD0 in
pu+chas during the anniversaryyea? and • : , "„
• i Did Pit If the purchases are pan of the purchisti. in rscets
of S3iDc'D during the anniversary year.
•?`"'a-"
Kd ';; ..
Arq purdhais mods at tern hvarrhosrse dubs'or dacovV rtdres
will be ineligible for a Tradhionil Cashbarl Sbnvi Award in
outs of 26th wins) of the amount of the Wrthesm However,
- it-
P?
ttrseyurdsasss+dfl mrtioue Sobtintlvdetin the iptal amount
Df: purrhises erode dvrG'g8iesaanirersas? :yeistand ;soed:ta
.detnrgrine the appfsable pergrs°tagi-rife IAT 4 above Sw: other
purtfasrs. Please ,oA 7•BD4$a).7B96 ar,vv'rsif: Dw,Wrb site at
t)&tovertard:mm'fx•a rat of these sefrc•ivarefidsae-dvbtahd
dsoount xtors ' . ' ' : - -<,. ,,.::->r:•:star' : ,.. r
i,:? .
TfiE tstal of the`se'caiivtaSoru fuss •eac?T'tnniirverrisry y[al', jE'4ye
atvved amcium! of the Traditional Cashbad Bonus award The
asaved ammart of the Traditional Caxhbad Bunts award wiA be
made ave4abk to Cardrrlembers u.deccribed belnstx prp iietd
the cond4tm tort=irkd,,.ip'peragiepfi; S:,below arB; met .?rc
ntarlatiod for the, T(atTitional tasfrbak='Sums 'award begins
again with the begjnning ?ftSch_anniversp'ryyee„?,?`
.. -1> '.•: err--: -
E Casdmambers may ale? WWI ra:.d; fmrm. timE Y? brie othu
Ceslsbatt acims awards {tt;-??1j inati
m rig a putzhase •a aiprrdf
ercfantl; the, tam's d Whim win bf disdosed.in the offer..
7t,ese pusshesa will re¢ive the award amourd dcsvibtd in the
offet They will not be considered qualifitd r ties for
?1°'Poser of determining the annual level of purchaser and
talcutating du Tndrfionaf Cuhbatk Bonus award unlea
odxrwise dsdosed in six offer. These other fsshback Bonus
awards w, acuue In tft Crshbart Bonus A¢ours in atimdanca
with these Term and Concr6onr unless an ahernative method of
dabursarnaM's disclosed in the oftu. In addnion, if, as of the
data D'sraver Card dpterminu whether a Cardmember has met
the tams of the offer, six CerdmerslDerr Account it closed at
[ardsxmber retain a Traditional Cachbick Bonus award'on
these purchases. The acwed amount of these other Cathbad
Bonus awards miff be made available to Cardmembers u
drtcibed below provided tfre condrbDrs contained in paragraph
S below an met
S. All Ceshbad Bonus awards .rill be held in the Cashbid Bonus
Account The Casbbatt -DDrisri amovrrt avvi'$ble. for
drburssmem's the sinwrit in the Cashback BonwdSccptssf as of
the, last day of ttir.Grdmembes'rprrvrovs -0rlfin•prriod.
HDwevm Cachbitk'Boms-awards•MAY -be: redeemed-.in
inmileaft of S20.oniy.•Cardrtiembers hive, no.righf to'irnved
Cashbark Bonsa amswrm of lea than S2Dmr "amDovtl m ifkinyhA
S20 igroememi >Y +? - •'._•%.?._
Oniy-Cardmembers in gocdrending with: open A¢pv;%U..may
access the att7ved:Cashbart BDhus awards.in ihe, Cutiback
Bonus A¢ovnt To be in9ood standing e Cardmembu may not
be, dermquen't (ti tfisbibrd bovv') sir in'defi (at defin=d 'm
the Cardmember ApiMmeRd. &at Cardmtriiber may nDi have
usrd the!:Aerovnt:-for.arry prohbhed: 7rznsscYiorss.-T}n
Cardmember is dennquerg,if;Q'µtovtriard barnot zetensrd:e
required payment by the-PAymem Due Date thpwrv on tht
moirih)y billing itater*rr;E - :: ..
)f in Acmurd s ieactive for 36 consecutive monthA any amount
'2D -
i? i
t. rnav??hkve
r in which"tashbatk Bonus awardL- are
a rredM1.:D the, Casdmembd s Acminvt
zD the Cardmembec or an exchange, DLthe
select more
meernesRt: DiseDVatrbtC;aiX:tlsngE tRq cederbption anelhads
in fiztstsk dfs¢FiiDrr fzomYime-to time. tf b the CaidmenS%1s
resyens THY to notify Discover card in the event a Cashbad
Bonus d sbursern"t is not racewed fw any reason.
Cerdmembers mat redeem Cashbask Barns awards by calling 1-
377-MAt AWARD (1-877.965-7232 fManday-Friday, 7am - 7pm
CM Dr on the Imem;i At Discwa urd.corn. Prig tD
redemption the Tbrsactiars on which Ctshback Bonin awards
are mt!vlatr6 may be audited for compliance, with these Terns
and Ca CF;Znt
7. In the event a Card's last yr stolen, the acvutd em'r,wrof the
Cashback Bonus awardi in the Cei'hbitk''BPw ui:n the
amov»i of t76afditiig purrhaseran?`tt'ie'zapiveiiary- a efrom
the Did Actouht vAl be tnnsferred'ttf theiieW'f ckourst " '•
8. Discover Card -reserves the, right to make other atiur'vntnt to
Cashbad BDnut amounts accrued based on Account acti ft.. far
example. any returns win decrtment their amovt as
detesminrd in Disraver Card's sole drst:retiors DlKpver Card also
resttm the right tD truncate r# round Cashbact8on}rt amounts
is the nearest cerd u determined in ;iti tole cr cri on. -d the
Cardrnzmber receives a Cashback Boma !"id in?erces of the
-" t-':. qlr. prrt•y ra-yt aav.°...
3. Then terms and tbndniDru.ark sobiect'i6 chirigi wrlhovl
notit= Changes may be mast it any line-Ind may intrv6k-bot
are not limited to, modifying the level of purchaaq.rtgvirtdso
qualify 4or the variDVs tiers, estabrrshiriia m_'zz+mvm emdsli cf
the amount of Cadrbark somas. ai
of ?ta'tfsaterx Sfn"poting addriipha
the program:
-77-
r
r :•a•d_y,
-1:
(
-• DESCRIPTIOR,OF
ymir Diimrit'Uek2 Card' fthd 'atdrt, ut3 'fir <fi;rge yriCA
entire Cemmdn Carrier Fare Ticket onsariy'Commtrcial Matill
opeMed by a'Scheduled Air. Carrier. W46--r' a:;1' TB -%far thi
transpar.Yt lon of pastngeri'for hire fhereirc mned S'dhrdu)ed
AP CarrM you autamatiolfy mbOve This rrzlueble wverape'At
rw'AddMorul cost. . ':.:::. :: ": _' .:•.:' ^; .: is ?s -
Tht•berie pCthe PcYrzypsoy.?drng yiwr tcnf ag z. rr gov'emsd
prirtihny, the liW b`{ r,,tiattp?}i:7??ie tt`faFdas. ;_.y ` ..
'Coverage h. undtrvrritYeI by'NattvnA. Unipn•Frt-ft;vmrm
CamPAY of FriithlagiyFYrfifse:')nsvran4;Com?tny?,-with
offices in New Yvrf;, NY. Catafn jIn tic, rs and:exctuforwappiy.
PLAN F£ATl1RE5 . - '
Sariefft AmorrntS150,0DD Family Aggregatt Principal Sum
ACI]DWAL DEATH BENEFITS. Insurance covtrape will be equal
to the btnefd amourd far aetidesml lvst of Gfe. The loss court
occur wr81n one year of she Accident that ?sustd 11,e Injury.
Family Agpre ate Principal Sum means the tOTAl amDW7I of
lnnaance in fgorce an the Cardmember, his or her spouse and
chairDepruhdentChildrenfa[,ar, PmAccident d.Mor than one
lint iced Pe scan discos the recut(d e;l yurig•rt eivti! 1c'z'rny
one awdert the'fami?y: A?gregbte PriFictpit turn. nidl3e. rtE
rated end paid in aaofdabce YX.the divri psi ,im itdbene-
fidwy Pran-Wars of the Wky. Once the Family Aggregate
Prfrsopal Sum k paid for any vne hound Peron in a family that
cmat u tie rmh of any one amides" no further benefits are
payable for further deaths in that Family due to )n)uriti received
in the Same accident
Masfmvm Acdtltntaf Death benefhr payable hmetr the Pclicjr, if
more than me cardmember sufferi a loss from :ht "Tame
accident ve lirrfitedrto an aggregate. of,S2oDDD,DDD.}at All
CilBdieinhbers rom`birje6 A'rg? rrduciioif Pf beriefsif ntcrsFif)? Tb
i?ritpg w}fii)firrlimitnvn Eb,di on-1 prbpat ?no e
bzsfr tb eat'rdmemh'r`rup td tlsit ec9;eie_limit bf lia6iGty'
bi' red h"ire q GrdmtmBer' ca lyric ninth r b { nY her
Intwad spouse rand insured dependtrit r},r(dr•_n, This aggregate
lvott:dM notrepLcr vain any. way imtrt tha famiSyAopregAte
Prindpal Sum' rteted under the Parry'. -
'Iniv`rY' means bvdrh kfurr. (a)rwhich a ivRairitd'zs`a'direR
?;:... ;.•___._•?._' vmvcacsq{ cayrae?;rcovtreo•msr;rj`-:•`.'s'..': .<; ."
"k."`k= :e-•-•sw s?p.a DiSAPREARANCE.iSf](EATS. 1Ne'wiQ'prtwmryvu tvfiefedivss Of
We out to an accident if you are riding in a Scsedv)ed A¢
ze -
hetlukS"Air CamleV. iF :Wrt[fe3ssints'ta
body o nvtfound wit Jh'Dne (1) rev of the
itY_pyyab(e for rev, yore il?asisr end`youf
ram the came A¢idtnt will not e?cceed the
EiJG1611.ITK Th's automatic fncunrxr'$ provided to cRyi>;fe
Wdert of the oedd mid whore names appear an the ttedrf
iar@,''dtew spouses' and their urvfarried depin-rat =hndren
under age ID (apt 23 if attetsdiri? school on afulFiime'bts$ and
fully de;,th6r ¢.pn you-Liar suppgrr). Howevt{ the age Gast ZIM
not Apply to v, chlld•,.sha:;•s inapabie ol,..ielf-sgstain)ng
' emplayrrrnt by teesdn of mestfal or physical inupadtZ'
EMCTM PATES. Your insurance under this plan Is effr5m on
the rata Of 1) July i, 2DD1; or 2) the date you betornr an eligible
Perion. Your insurance under this plan will cease an the earlier
of. )the date the irssurme cavenge c ttrm)nateet er 2) on the
date you Lease to be an eligible holder of the credit Lard.
THE NNEFIC]MM Unless you designate otherwise with a
Ixnefidary desigrrTion form your death benefit willbe pent, in
teival shares. to the fart svrJiving dam of those that faffo .. (1)
ryas =pause; W raw children: (3) your pafeni? ar 14) your
brothers and sisters. R no glass has. a ;wYw L the.beneficiary is
your crate. YOU may.iiW e.y linei p-ary'b' ^vdtihpo the
huvrance Company at Acddtid v Hea)tii DFvsm, m SOD Vilest
Madison Street, Svite 1750, CNcxpo, It MI.
CWM PROCEDUP.E. 'Daim fdrens maybe obtained through the
Insurance Company. Claims for benefra mist be filed with the
• Insurance Company within 90 days or as soon is vtasanably
possible after the ions DrsurL
PLAT! DF IN PANCE COVERAGE. YOU, as a Cardmember, and
your spouse and children. will be covered apafnd injuries that
MUM in en buiderds! death while As a pesv_nptvln or on,
including gettinp in or our of, or an or off Di. arty Schedultel Air
Carrier ff the Common Carrier Fare Ticket for the flight wss
charged to your credit mrd. -
Companion Ikketr kcutd for frr_ wth the pucbese of A fun.
fare mmmon carrier ticket and used by a spouse or deptndtnt
child will be considered as fully charged to the mi5h card, if the
corresponding iull common Carrier Fare Ticket is charped to the
credit card.
Coverage is efftc'nm when you board the Scheduled Air Carrier,
provided the full Common Carrier Fare Ticket ¢ purchased, or
the travel Mtrvation a madt for the companion tfckett prior to
bwe1ng such Scheduled Air Carrier. Coverage ends when'you+•
afight from the Scheduled Air Carrier.' '
i
fXC1USIDNS. 8entfiu ere not payable if The loss is caused by'rx:
results frame 1) self-irrmRed in)ury or svidde; 2);drieM dseesp
or mental irueparity or bodily infirmity whether dvettfy, cr
-73-
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to
unswom falsifications to authorities, that he/she is RnhPrt- Adk i n-
(Name)
Accounts Manager of Discover Financial Services Inc., servicing agent of the plaintiff herein, that
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint
in Complaint are true and correct to the best of his/her knowledge, information and belief.
4iWWR#U?{t???SY
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6
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-04006 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER
CREE DENISE B
VS
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
CREE DENISE B
was served upon
the
DEFENDANT
at 1822:00 HOURS, on the 22nd day of August , 2005
at 134 S 24TH ST
HILL, PA 17011 by handing to
WILLIAM CREE, HUSBAND
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs
Docketing 18.00
Service 12.00
Affidavit .00
Surcharge 10.00
.00
40.00
Sworn and Subscribed to before
me this day of
A.D.
Prot Lary
So Answers:
R. Thomas Kline
08/23/2005
WELTMAN WEINB G IS
By:
yV?
Deputy Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
DENISE B CREE
Defendant
No. 05-4006
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
WILLIAM T. MOLCZAN, ESQUIRE
PA I.D.447437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#0414059
Judgment Amount $ 4,226.13
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
DENISE B CREE
Defendant
TO THE PROTHONOTARY:
Civil Action No. 05-4006
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, DENISE B CREE above named, in the default of an Answer,
in the amount of $4,226.13 computed as follows:
Amount claimed in Complaint $3,726.13
Interest from date of judgment
at the legal interest rate of 6% per annum
Attorney's fees $500.00
TOTAL $4,226.13
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA
R.C.Y. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By -4i? Fj- --
WILLIAM T. MOLCZA SQUIRE
PA I.D.#47437
wettman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#0414059
Plaintiff s address is:
c/o Wellman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 134 S 24TH ST
CAMP HILL,PA 17011
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
DENISE B CREE
Defendant
05-4006-CIVIL
IMPORTANT NOTICE
TO:
DENISE B CREE
134 S 24TH ST
CAMP HILLRA 17011 ``\\ S
C
Date of Notice: ? V
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 NOTICE TO
A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAUREL LEGAL SERVICES INC.
206 SOUTH WATER ST.
KITTANING, PA 16201
(724) 548-7674
WELTMAN, WEINBERG & REIS CO., L.P.A
By:
William T?lMolczan, Esquj
PA LD.#47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #04141059
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
DENISE B CREE
Case no: 05-4006
NON-MILITARY AFFIDAVIT
Defendant
The undersigned, who first being duly sworn, according to law, deposes and states as follows:
That he/she is the duly authorized agent of the Plaintiff in the within matter.
Affiant further states that the within Affidavit is made pursuant to and in accordance with the
Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521.
Affiant further states that based upon investigation it is the affiant's belief that the Defendant, DENISE B
CREE is not in the military service.
Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data
Center (DMDC), which states that the Defendant, DENISE B CREE is not in the military service.
Further Affiant sayeth naught.
AFFIANT
SWORN TO AND SUBSCRIBED u1sny presence this y
of le_1 z - . ?`_,
NOTARY
rl.? ..
This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be
used for that purpose.
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members' Civil Relief Act
Page 1 of 1
OCT-06-2005 06:13:51
-' Last Name First(Middle Begin Date Active Duty Status Service/Agency
CREE Based on the information you have furnished, the DMDC does not
possess any information indicating that the individual is currently on
active duty.
Upon searching the information data banks of the Department of Defense Manpower Data Center, the
above is the current status of the individual, per the Information provided, as to all branches of the
Military.
j7?
Robert J. Brandewie, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act
[50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most
strongly encouraged to contact us by Fax at (703-696-4156) or by phone at (703-696-6762). We will
then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to
be invoked against you.
This response reflects current active duty status only. For historical information, please contact the
military services SCRA point of contact.
See: htV.//Www.defenselink.mil/faq/pis/PC09SLDR.html.
Report ID: BOTXJBAWMAH
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/6/2005
d
N r
d
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs, Civil Action No. 05-4006
DENISE B CREE
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Judgment was entered against you
on -OCA-Mlk5bs
(xx) Assumpsit Judgment in the amount
of $4,226.13 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
7
By:
PRO ONOTAR
DENISE B CREE
134 S 24TH ST
CAMP HILL,PA 17011
Plaintiffs address is:
c/o Wellman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219
1-888-434-0085
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
DENISE B CREE
Defendant
No.05-4006-CIVIL
STIPULATION OF THE PARTIES FOR
PAYMENT AND FOR THE ENTRY OF
JUDGMENT BY CONSENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan
PA I.D. 947437
WELTMAN, WEINBERG & REIS, CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#04141059
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 05-4006-CIVIL
DENISE B CREE
Defendant
STIPULATION OF THE PARTIES FOR PAYMENT
AND FOR THE ENTRY OF JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment in favor of Plaintiff and against the Defendant, DENISE B CREE , above-named, in
the amount of $3726.13 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by
Consent, as follows:
Defendant admits indebtedness to Plaintiff in the amount of $3726.13 with continuing interest thereon
at a rate of 6.00% per annum from DATE OF JUDGMENT, plus attorneys' fees in the amount of $500.00 and costs.
2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be
entered in favor of the Plaintiff and against the Defendant, DENISE B CREE , in the amount of $3726.13 plus
continuing interest thereon at the rate of 6.00% per annum from DATE OF JUDGMENT, plus attorneys' fees in the
amount of $500.00 and costs.
3. Plaintiff agrees not to Execute on its Judgment so long as Defendant causes to be delivered to Plaintiff
the following payments in full by 12:00 NOON on the following dates:
(a) $200.00 due by 12/20/05;
i
(b) no less than $200.00 per month due on the 20TH day of each consecutive month thereafter until
the Judgment amount plus acckued interest and costs are paid in full.
4. All payments are to be made payable to the order of "DISCOVER BANK"
5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg &
Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219.
6. In the event of default, each payment received shall be first attributed to costs, interest and then to
principal.
7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of
Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff
shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full
balance of the Judgment entered hereunder plus appropriate additional interest and costs.
8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a
waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation
which the parties agree is final and complete.
9. Intending to be legally bound, the parties set their hands and seals this -day of ,
20
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: ???_o
William T. Molczan?
PA I.D. 447437
WELTMAN, WEINBERG & REIS, CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(41.2) 434-7955
W W R#04141059
By:
Defen4Wir'NEI?TME B CREE
0
44
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
DENISE B CREE
Defendant
No. 05-4006-CIVIL
PRAECIPE FOR SATISFACTION OF
JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA. I. D.#47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#04141059
4
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 05-4006-CIVIL
DENISE B CREE
Defendant
PRAECIPE FOR SATISFACTION OF JUDGMENT
At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned
Judgment.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T. Molczan, Esquire
PA. I . D.#47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #04141059
Sworn to and subscribed
before met is a?
day of Jan
NOTA Y PU
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