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CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 1 of 18
IN THE SUMMIT COUNTY COURT OF COMMON PLEAS
SUMMIT COUNTY, OH
DISCOVER BANK
6500 NEW ALBANY ROAD EAST
NEW ALBANY, OH 43054
PLAINTIFF CASE NO.:
vs. JUDGE:
BRAD COOKE
803 BRIDGE RD
AKRON OH 44312-2313
DEFENDANT
COMPLAINT
1. Discover Bank is an FDIC-insured Delaware state bank and is licensed to do business
in the state of Ohio.
2. Upon information and belief, Defendant(s) is/are an individual(s) who reside(s)
and/or maintain(s) an address and/or domicile sufficient to allow the Court to maintain jurisdiction
and venue of Plaintiff’s claims.
3. Defendant(s) applied for and Plaintiff issued a credit card account to Defendant(s)
with a current account number ending in XXXX-XXXX-XXXX-8000 (the “Account”).
4. At the time the Account was opened, Plaintiff sent Defendant(s) a copy of the
Cardmember Agreement, which set forth the terms and conditions of the Account, to the address
provided by Defendant(s) on his/her/their application. A true and correct copy of the governing
Cardmember Agreement (“Agreement”) is attached hereto as Exhibit A.
5. The Agreement provides, in relevant part, that by use of the Account, Defendant(s)
became bound by the terms in the Agreement. Exhibit A, ACCEPTANCE OF AGREEMENT.
6. According to Plaintiff’s records, Defendant(s) used the Account, and thus accepted
the terms of the Agreement. See Account Statements, attached hereto as Exhibit B.
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7. Defendant(s) breached the terms and conditions of the Agreement by failing to pay
the balance due and/or make the required monthly payments.
8. The balance due and owing to Plaintiff is $10,263.60. See Exhibit B.
9. Throughout the life of the Account, Plaintiff sent Defendant(s) Account Statements
reflecting the charges and credits made on the Account and setting forth the total amount due.
10. Defendant(s) did not object to or otherwise contest these Account Statements within a
reasonable time.
WHEREFORE, Plaintiff, Discover Bank, prays for judgment against Defendant(s) in the
amount of $10,263.60, plus post-judgment interest on the balance at the statutory rate from the date
of judgment and court costs.
Respectfully submitted,
DISCOVER BANK
/s/ David Mullen
Kris Velayudhan (#0074606)
David Mullen (#0089053)
Sean Winters (#0084612)
Attorneys for Plaintiff
DISCOVER BANK
P.O. Box 3006
NEW ALBANY, OH 43054
Phone (800) 347-0212
Email: OH-
legalrecovery@discover.com
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CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 1 of 18 IN THE SUMMIT COUNTY COURT OF COMMON PLEAS SUMMIT COUNTY, OH DISCOVER BANK 6500 NEW ALBANY ROAD EAST NEW ALBANY, OH 43054 PLAINTIFF CASE NO.: vs. JUDGE: BRAD COOKE 803 BRIDGE RD AKRON OH 44312-2313 DEFENDANT COMPLAINT 1. Discover Bank is an FDIC-insured Delaware state bank and is licensed to do business in the state of Ohio. 2. Upon information and belief, Defendant(s) is/are an individual(s) who reside(s) and/or maintain(s) an address and/or domicile sufficient to allow the Court to maintain jurisdiction and venue of Plaintiff’s claims. 3. Defendant(s) applied for and Plaintiff issued a credit card account to Defendant(s) with a current account number ending in XXXX-XXXX-XXXX-8000 (the “Account”). 4. At the time the Account was opened, Plaintiff sent Defendant(s) a copy of the Cardmember Agreement, which set forth the terms and conditions of the Account, to the address provided by Defendant(s) on his/her/their application. A true and correct copy of the governing Cardmember Agreement (“Agreement”) is attached hereto as Exhibit A. 5. The Agreement provides, in relevant part, that by use of the Account, Defendant(s) became bound by the terms in the Agreement. Exhibit A, ACCEPTANCE OF AGREEMENT. 6. According to Plaintiff’s records, Defendant(s) used the Account, and thus accepted the terms of the Agreement. See Account Statements, attached hereto as Exhibit B. 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 2 of 18 7. Defendant(s) breached the terms and conditions of the Agreement by failing to pay the balance due and/or make the required monthly payments. 8. The balance due and owing to Plaintiff is $10,263.60. See Exhibit B. 9. Throughout the life of the Account, Plaintiff sent Defendant(s) Account Statements reflecting the charges and credits made on the Account and setting forth the total amount due. 10. Defendant(s) did not object to or otherwise contest these Account Statements within a reasonable time. WHEREFORE, Plaintiff, Discover Bank, prays for judgment against Defendant(s) in the amount of $10,263.60, plus post-judgment interest on the balance at the statutory rate from the date of judgment and court costs. Respectfully submitted, DISCOVER BANK /s/ David Mullen Kris Velayudhan (#0074606) David Mullen (#0089053) Sean Winters (#0084612) Attorneys for Plaintiff DISCOVER BANK P.O. Box 3006 NEW ALBANY, OH 43054 Phone (800) 347-0212 Email: OH- legalrecovery@discover.com 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 3 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 4 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 5 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 6 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 7 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 8 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 9 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 10 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 11 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 12 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 13 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 14 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 15 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 16 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 17 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0505 CROCE, CHRISTINE 02/14/2023 08:40:57 AM CMCO Page 18 of 18 23-1508 Sandra Kurt, Summit County Clerk of Courts