IN THE COURT OF COMMONPLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`CIVIL DIVISION
`
`DISCOVER BANK
`
`PLAINTIFF(S)
`
`CASE NO.:
`
`COMPLAINTIN CIVIL ACTION
`
`DAVID R BROWN
`
`DEFENDANT
`
`FILED ON BEHALFOF:
`PLAINTIFF
`
`COUNSEL OF RECORD OF THIS PARTY:
`
`MATTHEW W.POMY,ESQ.
`PA ID# 318403
`WELTMAN, WEINBERG & REIS, CO, L.P.A.
`436 7TH AVE., STE. 2500
`PITTSBURGH, PA 15219-1842
`412-434-7955
`WWR# 040818511
`
`

`

`IN THE COURT OF COMMONPLEAS OF ALLEGHENY COUNTY, PENNSYLVANLA
`CIVIL DIVISION
`
`DISCOVER BANK
`
`PLAINTIFF
`
`DAVID R BROWN
`
`DEFENDANT
`
`ARBITRATION DOCKET
`NO. si ee
`
`HEARING DATE
`
`_
`
`NOTICE TO DEFEND
`
`If you wish to defend against the claims set forth in the following pages, you
`YOU HAVE BEEN SUEDIN COURT.
`must take action within TWENTY (20) days after this complaint and notice are served, by entering a written appearance
`personally or by attorney and filing in writing with the court your defenses or objectionsto 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 orrelief requested
`by the Plaintiff. You may lose moneyor 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
`TELEPHONETHE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
`
`LAWYER REFERRAL SERVICE
`The Allegheny County Bar Association
`3rd Floor, Koppers Bldg
`436 Seventh Ave
`Pittsburgh, Pennsylvania 15219
`(412) 261-5555
`www.acbalrs.org
`
`HEARING NOTICE
`
`YOU HAVE BEEN SUED IN COURT. Theabove Notice to Defend explains what you mustdo to dispute the
`claims madeagainst you. If you file the written response referred to in the Notice to Defend, a hearing before a board of
`arbitrators will take place in the Compulsory Arbitration Center. Report to the Arbitration Assembly Room, Courtroom
`Two, Seventh Floor City-County Building, 414 Grant Street, Pittsburgh, Pennsylvania 15219, on
`,20 at 9:00 a.m.
`IF YOU FAIL TO FILE THE RESPONSES DESCRIBEDIN THE NOTICE TO DEFEND, A JUDGMENTFOR THE
`AMOUNTCLAIMED IN THE COMPLAINT MAY BE ENTERED AGAINST YOU BEFORE THE HEARING.
`
`DUTY TO APPEAR AT ARBITRATION HEARING
`If one or more of the parties is not present at the hearing, THE MATTER MAY BE HEARD AT THE SAME
`TIME AND DATE BEFORE A JUDGE OF THE COURT WITHOUT THE ABSENT PARTY OR PARTIES. THERE
`IS NO RIGHT TO A TRIAL DE NOVO ON APPEAL FROM A DECISION ENTERED BY A JUDGE.
`
`NOTICE:
`
`YOU MUST RESPOND TO THIS COMPLAINT WITHIN TWENTY (20) DAYS OR A
`JUDGMENT FOR THE AMOUNT CLAIMED MAYBE ENTERED AGAINST YOU BEFORE
`THE HEARING.
`IF ONE OR MOREOF THEPARTIES IS NOT PRESENT AT THE HEARING, THE MATTER
`MAY BE HEARD IMMEDIATELY BEFORE A JUDGE WITHOUT THE ABSENT PARTY OR
`
`PARTIES. THERE IS NO RIGHT TO A TRIAL DE NOVO ON APPEAL FROM A DECISION
`ENTERED BY A JUDGE.
`
`

`

`WELTMAN,WEINBERG & REIS CO., L.P.A.
`BY: MATTHEW W.POMY,ESQUIRE
`PAID. NO. 318403
`436 7TH AVE,, STE. 2500
`PITTSBURGH,PA 15219-1842
`PHONE:412-434-7955
`FAX: 412-434-7959
`EMAIL: PITLAW@WELTMAN.COM
`WWR# 040818511eeeap
`
`ATTORNEYFOR PLAINTIFE(S)
`
`DISCOVER BANK
`
`PLAINTIFF
`
`DAVID R BROWN
`
`DEFENDANT
`
`IN THE COURT OF COMMONPLEASOF
`ALLEGHENY COUNTY, PENNSYLVANIA
`CIVIL DIVISION
`
`CASE NO.:
`
`COMPLAINT
`
`Plaintiff, Discover Bank, is a banking institution organized underthe lawsof the State of
`
`Delaware with a servicing affiliate of Discover Products Inc., successor by merger to DB Servicing
`
`Corporation, whose business address is 6500 NEW ALBANY ROADE, NEW ALBANY, OH 43054.
`
`Discover Products Inc., is the servicingaffiliate for Discover Bank, an FDIC insured Delaware
`
`State bank. As the servicingaffiliate, Discover Products Inc., performsa variety of services for
`
`Discover Bank including, business managementservices in support of Discover Bank businesslines,
`
`including, among otherthings, credit cards, deposits, personal loans and student loans, customer
`
`service, collections, collection of delinquent accounts and other support services. The collection of
`
`delinquent accounts includesthe right to forward the accountto the attorneys and/or collection agencies
`
`for collection andto file suit on Discover Bank's behalf.
`
`Atall times pertinent hereto, Discover Products Inc., is the servicing affiliate for Discover
`
`

`

`DAVID R BROWN is adult individual(s) residing at 10 CHESTNUT ST NATRONA
`
`HTS, PA 15065-2640.
`
`Defendant applied for and received a credit card bearing the account number
`
`XXXXXXXXXXKX8E587.
`
`Defendant made use ofsaid credit card and has a current balance due of $5,335.88. A copy of
`
`Plaintiff's Statement is attached hereto, marked as Exhibit "1".
`
`Defendantis in default by failing to make monthly payments when due. As such,the entire
`
`balance is immediately due and payable to Plaintiff.
`
`Although repeatedly requested to do so by Plaintiff, Defendant has failed to pay the balance due the
`
`Plaintiff.
`
`WHEREFORE,Plaintiff prays for Judgment in its favor and against Defendant, DAVID R
`
`BROWN,individually, in the amount of $5,335.88 plus costs and statutory post judgment interest.
`
`Weltman, Weinberg & Reis Co., L.P.A.
`
`“MATTHEW W. POMY,Esquire
`Attorneysfor Plaintiff
`
`

`

`VERIFICATION
`
`
`
`—VisePhjigs ElvesgpeedlcDrdiasts,
`
`(Title)
`(Name)
`Of Discover Products Inc., successor by merger to 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. § 4904relating to unsworn falsifications to authorities states, that he/she is a duly authorized
`representative of plaintiff herein. Additionally, he/she verifies that Discover Bank, which is an FDIC
`insured Delaware state bank, lacks sufficient knowledge or information to verify this complaint.
`
`He/sheverifies that he/she is authorized to makethis verification. As an employee of Discover
`
`Products Inc., successor by merger to DB Servicing Corporation, he/she has sufficient knowledge
`and information to makethis 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 accountand therelationship between Discover Bank and
`Discover Products Inc., successor by merger to DB Servicing Corporation.
`
`It is further stated that Discover Bank extends credit through issuance of the Discover Card. Asthe
`servicing affiliate, Discover Products Inc., performs a variety of services for Discover Bank,
`including business managementservices in support of Discover Bank businesslines, including,
`amongotherthings, credit cards, deposits, personal loans and student loans, customer service,
`collections, collection of delinquent accounts and other support services. The collection of
`delinquent accounts includesthe right to forward the sameto the attorneys and/or collection
`agenciesfor collection andto file suit on Discover Bank's behalf. Both Discover Products Inc., and
`Discover Bank are wholly owned subsidiaries of Discover Financial Services.
`
` Date_JJs2%o-Dj
`
` (Signature) Yick7 AR Ths
`
`Discover Products Inc., successor by mergerto
`DB Servicing Corporation servicing Affiliate For
`Discover Bank
`
`DAVID R BROWN
`
`Client #XXXXXXXXKXXXX8587
`WW R# 040818511
`
`

`

`CERTIFICATE OF COMPLIANCE
`
`I certify that this filing complies with the provisions of the Public Access Policy ofthe
`
`Unified Judicial System ofPennsylvania: Case Records ofthe Appellate and Trial Courts that
`
`require filing confidential information and documents differently than non-confidential
`
`information and documents.
`
`Weltman, Weinberg & Reis Co., L.P.A.
`
`+4&e—Z
`MATTHEWW.POMY, ‘Gue
`
`PA I.D. NO. 318403
`436 7TH AVE., STE. 2500
`PITTSBURGH,PA 15219-1842
`Phone: 412-434-7955
`Fax: 412-434-7959
`Email: PPTLAW@WELTMAN.COM
`WWR#040818511
`
`Rev. 09/2017
`
`