Complaint,Petition: Discover Bank vs Sam H Sbeiti

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                                DISCOVER BANK IN THE DISTRICT COURT
Plaintiff
ee JUDICIAL DISTRICT
SAM H SBEITI FORT BEND COUNTY
Defendant(s)

PLAINTIFF’S ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:

DISCOVER BANK, (“Plaintiff”), complains of SAM H SBEITI, (“Defendant(s)”), and for its

cause of action would respectfully show the Court as follows:
This cause of action is governed by the rules for Expedited Actions under the Texas
Rules of Civil Procedure Rule 169 because the Plaintiff is seeking only monetary relief of

hundred and fifty thousand dollars or less excluding interest, statutory or punitive

damages and penalties, and attorney's fees and costs. Discovery is intended to be
conducted under Level 1 of Rule 190.2 of the Texas Rules of Civil Procedure. Damages
sought are within the jurisdictional limits of the court.
Plaintiff isa FDIC ured Delaware State Bank. Plaintiff may be contacted through the

undersigned attorney.

DISCOVER BANK SAM H SBEITI
Plaintiffs Original Petition
93720306013. Defendant(s) is/are a resident(s) of FORT BEND County, Texas, and may be served with
process at 2530 JESTER LN, STAFFORD, TX 77477. Venue is proper in this Court
because Defendant(s) resides/reside in this county at the time of the filing of this suit.

BREACH OF WRITTEN CONTRACT

4. Defendant(s) obtained a credit account from Plaintiff. The credit account is identified as
ending in account number i

5. Plaintiff and Defendant(s) entered into a credit account agreement (“the Agreement”).
Under the terms of the Agreement, Plaintiff rendered credit services to Defendant(s).
Defendant(s) accepted the credit services and under the Agreement became bound to pay
Plaintiff the amounts of such credit services, plus additional amounts due under the
Agreement.

6. Defendant(s) has/have failed to repay all of the credit services rendered under the
Agreement. The current balance due, owing and unpaid under the Agreement, after
allowing all just and lawful payments, credits and offsets, is $17,138.02. The terms of
the Agreement control the accrual of additional charges, interest, and other amounts.
Plaintiff has made demand upon Defendant(s) for payment of the balance due under the
Agreement, but Defendant(s) has/have failed to pay the balance.

7. All conditions precedent to Plaintiffs right to bring suit on its claims have been

performed or have occurred.

DISCOVER BANK V. SAM H SBEITI
Plaintiffs Original Petition
269372030601Wherefore, Plaintiff demands judgment in the amount of $17,138.02 against
Defendant(s), plus post-judgment interest, and court costs to the extent permitted by applicable

law.

Respectfully submitted,

ZWICKER & ASSOCIATES, P.C.

A Law Firm Engaged in Debt Collection

Attomeys for Plaintiff

14090 SW FREEWAY, SUITE 408

SUGAR LAND, TX 77478

TEL: (281)494-0300

FAX: (281)494-0213

EMAIL: ZATE_LITIGATION@ZWICKERPC.COM

[ ]JOHNETTA LANG, ESQ.
State Bar Number 24036943

[ ] TREVON WATSON, ESQ.
State Bar Number 24125451

[ ] TABITHA HAYNES, ESQ.
State Bar Number 24118986

{A DEIDRE HARRIS, ESQ.
State Bar Number 24058586

[ ] AJEET BADESHA, ESQ.
State Bar Number 24125994

DISCOVER BANK V. SAM H SBEITI
Plaintiff's Original Petition
269372030601