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HomeMy WebLinkAbout02-2781COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK, BY ITS AGENT, DISCOVER FINANCIAL SERVICES, INC., Plaintiff VS. : CIVIL ACTION TRACY L. FURJANIC, Defendant NOTICE 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 IS SERVED, BY ENTERING A WRITTEN 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 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. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE 4TM FLOOR CARLISLE, PA 17013 (717) 240-6300 DOUGLAS M. MARINOS & ASSOCIATES, P.C. Allentown, PA 18104 (610)434-2814 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK, BY ITS AGENT, DISCOVER FINANCIAL SERVICES, INC., Plaintiff VS. TRACY L. FURJANIC, Defendant COMPLAINT : CIVIL ACTION : CASE NO.:{~)& 1. Plaintiff, Discover Bank, by its agent, Discover Financial Services, Inc., ("Discover") is a banking institution with an address of P.O. Box 15251, Wilmington, DE 19886- 5251. 2. Defendant, Tracy L. Furjanic, is an adult individual with an address of 5 Crescent Drive, New Cumberland, Cumberland County, Pennsylvania 17070-2702. 3. Discover issued the Defendant a credit card subject to the terms of the Cardmember Agreement ("Cardmember Agreement"). A true and correct copy of the Cardmember Agreemem is attached hereto, made a part hereof and marked as Exhibit "A". 4. Defendant has incurred charges for purchases, cash advances and/or finance charges in the amount of TEN THOUSAND NINE HUNDRED ONE and 20/100 DOLLARS ($10,901.20) as of March 26, 2002. 5. Defendant's obligations are based on a subsisting debt, was in writing and arises from a preexisting account. 6. Defendant has not objected to account statements issued. 7. Defendant is liable to Discover on this debt as an account stated. 8. Defendant has defaulted on her obligation to make payments to Discover by failing to make any payments from and after January 9, 2002. 9. Pursuant to the Cardmember Agreement, Discover may declare all mounts due under the Cardmember Agreement immediately due and payable without notice or demand. 10. Under the Cardmember Agreement, Defendant is required to pay all the attorney's fees Discover incurred in exercising its right to collect, which Discover anticipates to be in the amount of FIVE HUNDRED and 00/100 DOLLARS ($500.00). 11. As of March 26, 2002, Defendant is indebted to Discover under the Cardmember Agreement in the amount of TEN THOUSAND NINE HUNDRED ONE and 20/100 DOLLARS ($10,901.20), plus interest accruing from and after March 26, 2002 at the per annum rate of 6%. WHEREFORE, Discover demands judgment against the Defendant in the amount of ELEVEN THOUSAND FOUR HUNDRED ONE and 20/100 DOLLARS ($11,401.20) (comprised of real debt in the amount ofTEN THOUSAND NINE HUNDRED ONE and 20/100 DOLLARS ($10,901.20) and anticipated attorney's fees in the amount of FIVE HUNDRED and 00/100 DOLLARS ($500.00)) plus interest from and after March 26, 2002, at the per annum rate of 6% and costs of suit. DOUGLAS M. MARINOS & ASSOC~~.C. ~ ;gS~m~j~1~ fBf o u, e v a r d Allentown, PA 18104 (610)434-2814 VERIFICATION Discover Bank, by its agent, I, Tracey ~cc]es, agent of Discover Financial Services, Inc,. verify that I am authorized to make this Verification on behalf of the Plaintiff and I verify that the facts contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.