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`SELIP & STYLIANOU, LLP
`10 Forest Avenue - Suite 300, P.O. Box 914
`Paramus, NJ 07653-0914
`201-368-2850
`Attorneys forPlaintiff
`S&S #: D161049
`
`DISCOVER BANK
`
`PLAINTIFF,
`
`-AGAINST.
`
`BLAIR E MILLER
`
`
`
`DEFENDANT(S).
`
`FILE NO. D161049
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`DOCKET NUMBER DC-003825-20
`POSIVISION OF NEW JERSEY
`
`MERCER COUNTY
`SPECIAL CIVIL PART
`
`FORBEARANCE AGREEMENT AND STIPULATION OF SETTLEMENT
`
`THIS AGREEMENTis made on October 8, 2020, between DISCOVER BANK(the "Creditor") and
`Blair E Miller (the "Consumer").
`
`1. Consumer consents to the jurisdiction of this Court and admits to the service of the summonsand
`complaint.
`
`Consumer hereby waives any andall offsets, defenses and/or counterclaims.
`
`Consumer agrees to pay to Creditor in full settlement of account number ending in 5879 (the
`"Account") the amount of $2,700.00 on or before November 9, 2020.
`
`All payments shall be made payable to DISCOVER BANK. Consumer may forward paymentsto Selip
`& Stylianou, LLP, P.O. Box 366, Woodbury, NY 11797-0366, or pay online at www.seliplaw.com,or
`by calling (866) 712-8982. All payments are subject to collection.
`
`In the event that the Consumershall default in making anyof the payments required hereunder, then
`Creditor shall mail written notice of the default to the Consumer. If the default remains uncuredfor ten
`(10) days from the mailing ofthe notice, then the entire amount claimed in the complaint, less a credit
`against same for any payments made hereunder, shall immediately be due and payableat the option of
`the Creditor and without further notice and demand.Insuchan.event, Creditor mayrequest thatthe
`court enterjudgmentfor the amount requestedin the complaint, less a creditfor anypayments made
`pursuant to this Agreement. The request forjudgmentmay includePrincipal,interest, ‘applicable.costs,
`and disbursements aspermitted by law.
`.
`
`Once Creditor receives the full amount Consumer has agreed to pay pursuant to this Agreement,
`Creditor will file a Notice of Discontinuance with prejudice with the court and will provide to Consumer
`written confirmation that the Account is settled for the amount agreedto.
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`7.
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`Uponsigning of this agreement, Consumer releases and discharges Creditor, its agents, and its
`attorneys, including Selip & Stylianou, LLP (the "Releasees"), from all claims of any kind, including
`violations under the Fair Debt Collection Practices Act and applicable state laws, that the Consumer may
`have with respect to the Account, including all claims that were asserted or could have been asserted in
`this action and any claims stemming from debt collection efforts of Releasees. Upon payment ofall
`amounts due pursuantto this Agreement, the Creditor releases and discharges the Consumerfromall
`claims of any kind, both known and unknown,that the Creditor may have with respect to the Account,
`including all claims that were asserted or could have been assertedin this action.
`
`This is a legally binding document. Consumer acknowledgesthat he/she has carefully read and fully
`understandsall of the provisions and effects of this Agreement. Consumer acknowledgesthat he/she has
`had a reasonable time to review this Agreement and fully understands the terms of the Agreement and
`signs it voluntarily. Consumer should consult an attorney before signing. Consumerfurther
`acknowledgesthat if he/she has voluntarily chosen not to consult an attorney of his/her choice to discuss
`the aspects of this Agreementthat he/she is voluntarily and knowingly entering into this Agreementfree
`of coercion and duress.
`
`In witness whereof, the parties hereto have set forth their handsand seals on the date herein
`above written.
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`Street Address
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`23 Ocle1and Stree
`Fraucn , NF oS SO
`City,StateAnda
`(Ol0}eloS- Zod]
` Blair E Miller
`
`ame Phoné Number
`
`Consumer (Signature Above)
`
`By: Mitchell Selip /#tafry Stylianou /
`Andrew Tealer / Daniel H. Adler, Esqs.
`Selip & Stylianou, LLP
`Attorneys for Creditor
`File No. D161049
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