On May 31, 2023 a
Complaint,Petition
was filed
involving a dispute between
Discover Bank,
and
Correa, Alfonso L,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
5/31/2023 2:45 PM
FELICIA PITRE
Insert text here DAfi'igggT’ $E§§§
Gay Lane DEPUTY
DC-23-07175
NO.
DISCOVER BANK, § IN THE DISTRICT COURT
Plaintiff § 134th
V. § JUDICIAL DISTRICT
§
ALFONSO L CORREA, § DALLAS COUNTY, TEXAS
§
Defendant(s) §
PLAINTIFF’S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
DISCOVER BANK, (“Plaintiff’), complains of ALFONSO L CORREA, (“Defendant(s)”), and
for its cause of action would respectfully show the Court as follows:
1. 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
two-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.
2. Plaintiff is a FDIC-insured Delaware State Bank. Plaintiff may be contacted through the
undersigned attorney.
DISCOVER BANKV. ALFONSO L CORREA
Plaintist Original Petition
266095030613
3. Defendant(s) is/are a resident(s) of DALLAS County, Texas, and may be served with
process at 633 STONEHENGE DR, GRAND PRAIRIE, TX 75052. 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 905.
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 lawfiil payments, credits and offsets, is $8,013.40. 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. A11 conditions precedent to Plaintist right to bring suit on its claims have been
performed or have occurred.
DISCOVER BANKV. ALFONSO L CORREA
Plaintist Original Petition
266095030613
Wherefore, Plaintiff demands judgment in the amount of $8,013.40 against Defendant(s),
plus post-judgment interest, and court costs to the extent permitted by applicable hw.
Respectfufly submitted,
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
Attorneys for Plaintiff
17950 PRESTON ROAD, SUITE 750
DALLAS, TX 75252
TEL: (833)510—2100
FAX: (972)591—0468
EMAIL: ZATDLIT@ZWICKERPC.COM
BY: LTIMOTHY
W Qz,
[ ] L.‘ELDER¢ESQ.
State Bar Number 00784013
[ ] ANTONY J. CHERIAN, ESQ.
State Bar Number 24087291
[ ] OLUWATOYOSI J. THOMAS, ESQ.
State Bar Number 24118554
[ ] VALENCIA R. CARTER-BENNETT,
ESQ.
State Bar Number 24071076
[ ] CONSTANCE B. MUTONG, ESQ.
State Bar Number 24104765
[ ] RAFAEL SIERRA, ESQ.
State Bar Number 24081494
V STATE
L. Mel Stimpson Jr.
BAR NUMBER 24115601
DISCOVER BANKV. ALFONSO L CORREA
Plaintiff s Original Petition
266095030613
Document Filed Date
May 31, 2023
Case Filing Date
May 31, 2023
Category
CNTR CNSMR COM DEBT
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FILED 5/31/2023 2:45 PM FELICIA PITRE Insert text here DAfi'igggT’ $E§§§ Gay Lane DEPUTY DC-23-07175 NO. DISCOVER BANK, § IN THE DISTRICT COURT Plaintiff § 134th V. § JUDICIAL DISTRICT § ALFONSO L CORREA, § DALLAS COUNTY, TEXAS § Defendant(s) § PLAINTIFF’S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: DISCOVER BANK, (“Plaintiff’), complains of ALFONSO L CORREA, (“Defendant(s)”), and for its cause of action would respectfully show the Court as follows: 1. 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 two-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. 2. Plaintiff is a FDIC-insured Delaware State Bank. Plaintiff may be contacted through the undersigned attorney. DISCOVER BANKV. ALFONSO L CORREA Plaintist Original Petition 266095030613 3. Defendant(s) is/are a resident(s) of DALLAS County, Texas, and may be served with process at 633 STONEHENGE DR, GRAND PRAIRIE, TX 75052. 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 905. 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 lawfiil payments, credits and offsets, is $8,013.40. 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. A11 conditions precedent to Plaintist right to bring suit on its claims have been performed or have occurred. DISCOVER BANKV. ALFONSO L CORREA Plaintist Original Petition 266095030613 Wherefore, Plaintiff demands judgment in the amount of $8,013.40 against Defendant(s), plus post-judgment interest, and court costs to the extent permitted by applicable hw. Respectfufly submitted, ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection Attorneys for Plaintiff 17950 PRESTON ROAD, SUITE 750 DALLAS, TX 75252 TEL: (833)510—2100 FAX: (972)591—0468 EMAIL: ZATDLIT@ZWICKERPC.COM BY: LTIMOTHY W Qz, [ ] L.‘ELDER¢ESQ. State Bar Number 00784013 [ ] ANTONY J. CHERIAN, ESQ. State Bar Number 24087291 [ ] OLUWATOYOSI J. THOMAS, ESQ. State Bar Number 24118554 [ ] VALENCIA R. CARTER-BENNETT, ESQ. State Bar Number 24071076 [ ] CONSTANCE B. MUTONG, ESQ. State Bar Number 24104765 [ ] RAFAEL SIERRA, ESQ. State Bar Number 24081494 V STATE L. Mel Stimpson Jr. BAR NUMBER 24115601 DISCOVER BANKV. ALFONSO L CORREA Plaintiff s Original Petition 266095030613