Preview
MOTION FOR DEFAULT FOR STATE OF CONNECTICUT
FAILURE TO APPEAR, JUDGMENT SUPERIOR COURT
AND ORDER FOR WEEKLY PAYMENTS
JO-CV-49 Rev. B99.
www jud.ct.gov
INSTRUCTIONS TO PLAINTIFFIPLAINTIFF’S ATTORNEY RETURN DATE
AA {EA
PLB 89 17-23, at seq Complete this Motion and an Affidavit of Debt (J0-CV-52) and send original of each 06/27/23
to the Clerk's Office and ene copy of each fo all defendants. Complete section f of
the Notice ofJudgment and Order for Weeidy Payments (JO-CV-50} and file in DOCKET NO.
TO: The Superior Court duplicate with the Clerk's Office. MMX-CV236037915S
ADDRESS OF COURT (No., sireet, town and zip coda}
Babee
Housing
Sassion Ele.a. no. Middlesex Judicial District 1 Court St., Middletown CT 06457
NAME OF CASE (Plaintiff v. Defendant)
Discover Bank V. CORA WILLIAMS
NAME(S) OF ALL DEFENDANT(S) AGAINST WHOM MOTION IS FILED:
CORA WILLIAMS.
a
SE MOTIO! LURE TO, IGMENT: AND ORDE! IR WEEK' MEN)
In the above entitled action, the Pleinti( (s} respectfully represents) that the Defendant(s) na med above has (have) failed to
file an appearance within two days after the return date. The Plaintiff(s) therefore request(s) that a default bé entered
against the Defendant(s) for failure to-appear and that the Court enter judgment after default in favor of the Plaintiff(s} in
accordance with the Affidavit of Debt‘attached. ("X” one of the following)
The Plaintiff(s) also request(s) that an order for D3 NOMINAL LJ REASONABLE $35.00___ weekly payments be entered.
NAME OF PERSON SIGIING MOTION, ADDRESS
Laurie D. Baron, Esq{(444; 53 Stiles Rd. Suite A102, Salem, NH 03079
‘SIGNED Clecantie
= i =
Blarrorney
For PLAINTIFF(S} TX
Le GS Be ae a me Y SERVICE AFFIDAVIT me Ae
The unde ig ned, ing duly worn, de leposes and cays that: ('X" one of the following)
(7 the undersigned is unable to determine whether or net the Defendant(s) in this action are in the military or naval service
of the United Siates.
i no Defendant in this action is in the military or naval service of the United States, and that, to the personal knowledge
of the undersigned (siate facts showing defendant is not in such service):
1. Defendant resides at: 14 CLOVER ST MIDDLETOWN, CT 06457-5219
2. The undersigned conducted a search by Defendant's name and Social Security Number on the Department of
Defense website: bups:’’vww.dmdc.osd.milappj/sora/seraHome.do
SIGNED (ata)
Ko
PRINT NAME AND, 1F APPLICABLE, TITLE, OF AFFIANT {PE SIGNED
LAL
SIGNED (Conlon of Si
Subsclned and sworn to before me:
eSES INTIFEIS BILL: STS:
=
ue Se
x 5 ae] 22
OF SERVI
This is to certify that copies of the above Motion, Miltary Service Affidavit,
Complaint Fee. Affidavit of Debt, and Plaintiff's Bill of Costs re gehyeredimailed via
Entry Fee..... $360.00 U.S. Mail, postage prepaid on (date): “17
Sheriffs Fee... $90.23 to the following Defendants: (Enter name(s) and address(es) of
Proceedings Before Trial Defendani{s)).
CORA WILLIAMS: ss
14 CLOVER ST
TOTAL. $450.23
4295398
oe"Teer
\
SIGNED C1 uate FOR COURT USE ONLY.
x Z. BR] ATTORNEY FOR PLAINTIFFS)
DATE SIGNED
7
Department of Defense Manpower Data Center Results as of : Jub42-2023 03:04:16 ALE
«ce SCRA 5.17
&
By Status Report
B
Pursuant to Servicersembers Civil Relief Act
nine
SSN: Guam
Birth Date: Game
Last Name: WILLIAMS
First Name: CORA
Middle Name:
Status As Of: Jul-12-2023
Certificate ID: 953YLCMDJX3SWHP
Aative Duly On Active Buty, ‘Date
= ‘Abtive
Duty Bnd Dat
NA Se ommpacient
No: NA
This responsa eel 8 ndciduale' active duty status based on the Activa Duly Status Date
Active Oiuly Wihit 367 Daya of Active Duly Siatus Date
‘Active Duly Stazt Dale ipEnd Date Stats
NA fice Conmpanaat
Ne NA
‘This response reftac!s idual oft ack yaa tn 357 dae procaine Duty Status Date
Momberor Fister Unt Was Natifed Futute Gall-ip to Ac ¢ Dano ike Duty Siawa Bala
2 Noliication Siar 1s rier Notiienuan
End Dato, ‘Setviee Compsront.
NA NA
This raeponse reftects whethor the inci Tun has. aly i jon to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Ceriter based on the informatio
n that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed
Servi ices (Army, Navy. Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or histher
unit re receiving notification of future orders to report for Active Duty,
ama Oleh, ada
Sam Yousefzadeh, Acting Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04£25
Alexandria, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense
(DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibitity for military
medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (60 USC App. § 3901 at seq,
the Scidiers' and Sailors’ Civil Relief Act of 1940). OMDC has issued hundreds of thousands
as amended) (SCRA) (formerly known as
of “does not possess any information indicating that the
individuat is currently on active duty” responses, and has experienced only a small error rate. tn the event the individual refe:
member, friend, or reprasenlative asserts in any manner that the individual was on active duty for
renced above, of any family
the active duty status dat te, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged.to obtain further verification of the person's
status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (Q38) via this URL: hitps:#/sera
.dmdc.osd.mil/scra/#Maqs. If you have evidence the person
was on active duty for the active duty status date and you fail to obtain this additional Service
verification, punitive provisions of the SCRA may be invoked
against you. See 80 USC App. § 3921(c).
This response reflects the following information: (1) The individual's Active Duty slatus-on the Active
Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early
notification to report for active
duty on the Active Duty Status Date.
More information on “Active Duty Status”
Active duty status as reported in tis cartficate ts defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of
than 30 consecutive days in length were available.
the active duty periods less
in the case of a member of the National Guard, this includes service under a call to active
service
authorized by the President ar the Secretary af Defense under 32 USC § 502(f) for purposes
of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members
must be assigned against an authorized mobilization position in the
unit theysupport. This includes Navy Training and Administration of the Reserves (TAR), Marine Corps Active Reserve (ARs) and Coast
Program Administrator {RPAs). Active Duly stalus-also applies to a Uniformed Service
Guard Reserve
member who is'an active duty commissioned officer of tha U.S.
Public Heatth Service or the National Oceanic and Atmospheric Administration (NOAA
Commissioned Corps}.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRAis broader in some cases and includes some calegorias of persons on active duty for purposes
reported as on Active Duty under this certificate. SCRA protections
of the SCRA who would not be
are for Tille 10 and Title 14 active dul ly recerds for all the Uniformed Services periods.
Tile 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10.
USC § 10144; NC).
Many times orders are amended to extend the pertod of active duty, which would extend
SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections
are based have nol t been amended to extend the inclusive. dates of service.
Furthermore, ‘some protections of the SCRA may extend to persons who have received orders to. report for active duty or
to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Dui ty entry is important because
extend beyond the last dates of active duty. a number of protections of the SCRA
Those who could rely on this certificate are urged to seek qualified fegal counsel
to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based ona fast name, SSN/date of birth,
and active dut ly stalus date provided by the requester. Providing
erronecus information will cause an erroneous certificate to be Provided.
ce
AFFIDAVIT OF DEBT
RE: MOTION FOR DEFAULT
CONTA
FOR FAILURE TO APPEAR, STATE OF CONNECTICUT
JUDGMENT AND ORDER FOR SUPERIOR COURT
WEEKLY PAYMENTS
JD-CV-52 Rev. 5-99 INSTRUCTIONS
PLB 617.25
1. Complete this offdav# and end ariginal with your completed Motion for Dataultto Appear, Judgment and Order
for Weekly Payments (JD-CV-49) and Motice of Judgment and Order of Payments (dD /-50} to the Cierk’s Office
2, Alach a copy of the contact, lease or ather decumant, H applicable. lo the completed affidavit.
3. interest is being claimed, the period covered
and the ras claimed must be slated.
4. lfciaiming attorney's fees, a copy
of the agreement must be attached.
5. Send one copy of tine completed Affidavit and Motion to each defendant, RETURN OATE
06/27/23
TO: The Superior Court DOCKETNi
MMX~-CV231 20379158
ce
JUDICIAL HOUSING GA ADDRESS OF COURT (No, sireet fown, end zip coda}
DISTRICT SESSION NO. Middlesex Judicial District 1 Court St., Middletown CT 06457
NAME OF CASE (Plattif v, Defendant)
Discover Bank V. CORA WILLIAMS
NAME(S) OF (ALL) DEFENDANT(S) AGAINST WHOM MOTION IS FILED
CORA WILLIAMS
oe ee es
ERIDAVIT: EBT
The undersigned deposes and says that (s)he is the Gj Plaintiff or XK (tite) Attorney of the
Plaintiff
and is familiar with the facts stated below, The Defendant(s) is/are indebted to the Plaintiff(s) as follows:
A detailed affidavit of debt, executed by the Plaintiff, Discover Bank is attached hereto and made a part
hereof.
This communication is from a debt collector.
4295398
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& Continuation of this isPROT OF PR is atiached and made a part hereof. 2S.\
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‘SIGNED (Alfani)
eZ
PRINT NAME OF AFFIANT.
BARON LAURIE (444211(CT))
—— NED (Comm, of Sup. Courl/Notaryy
Subscribed and swon re me: TE SIGNED
ACCOUNT NUMBER: XXXXXXXAXXXX9267
BALANCE: $5,792.28
CARDMEMBER (§): CORA WILLIAMS
STATE OF OHIO
COUNTY OF FRANKLIN
Janice Dorr, personally appeared before ime, on this day
and after bei ing duly sworn, according to law, and
upon my oath and states as follows:
Tam a Litigation Support Coordinator for DISCO’ VER BANK
, an FDIC-insured Delaware state bank.
DISCOVER BANK, as well as its whol! ly-owned servicin,
ig subsidiary DISCOVER PRODUCTS INC,, is
responsible for, among other things, interacting with
Dise ‘over Card account h elders to accept payments and
perform other servicing activities on Discover Card accoun
ts.
This affidavit is made on the basis of m 'y personal knowl
edge, as well as m' y review of documents held both
ISCOVER BANK and DISCOVER P. by
account against the Cardmember(s).
RODUCTS INC,, an id is submitted in support of the Plaintiffs suit on
In my capacityas Litigation Support Coordinator, Thave knowledge regarding, and
regarding the Discover Card account of the above access fo, records
referenced Cardmembei r(s). These records are maintained
in the ordinary course of business, and the records are uj ipdated with
and payments on the account) by individuals with information on events (such as charges
perso! nal knowledge of those events or by automated
processes that track such events at or near the
time that the events occur. The same systems that record
information also generate periodi ic statements that this
are sent to Discover tardmember(s), and store
these periodic statements. In addi ition, these copiés of
same: tecord-keeping systems contain informatio
version of DISCOVER BANK? s terms and conditions n about which
has been communicated to an account holder and
accepted. by an account holder through the use of
his or her Discove t Card after receipt of the tenns
conditions, Ihave personally inspected and
the records pertaining to th account of the Cardm
including the last periodic stat ement sent to the ember(s),
Cardmember(s), to ascertain the applicable terms
conditions, the balance due-.o1 n said accou and
nt and whether the Car ‘dmember(s) haye made
balance, paymenis on that
According to.the records maintained b: y DISC
OVER BANK and DISCOVER. PRODUCTS
period of time that account statements Were gener INC. during the
ated, such statements y were either provid
Cardmember(s) electronically or maile d ed to the
to the Cardmember(s) at the ad dress maintained
time period, According to the Tecords, on file during that
the last known address associa! fed with the Cardmember
(s) is/are:
14 CLOVER ST
MIDDLETOWN, CT 06457-5219
The account is in default because the Cardmember
(s) have not paid the amounts due and owing
BANK on the account. to DISCOVER.
The business records maintained by Di TISCOVER
BANK and DISCOVER PROD! UCTS INC., and
above, show that the Cardmember(s)’ accoun described
t with DISCOVER. BANK is govel med by terms and conditions
referred to as “terns level 28K." A. tru € and
correct capy of these terms and co: ditions have
DISCOVER BANK’s counsel in this ¢: ase. been provided to
Exhibit A is a true and accurate copy of the
last Periodic statement sent by DISCOVER PROD
the Cardmember(s), retrieved from the recor UCTS ING. to
d-ke eeping system described above.
SCB_WILLIAMS_1556225_1.2
v12
Exhibit B is a true and accurate copy of information retrieved from DISCOVER PRODUCTS INC.’s
record-keeping system that shows the current balance due and owing on the. Cardmember(s)’
account.
Exhibit B reflects the balance that includes any activity occurring on the account after the last statement
(Exhibit A).
DISCOVER BANK has access to a system of records maintained b y the United States Departmen
t of Defense,
which allows DISCOVER BANK. to ascertain whether a particular person is engaged in active
duty in any
branch of the U.S. military. It is the regular practice of DISCOVE! R BANK to query this system with
respect fo
any account holder prior to initiating a collection action against that account holder. DISCOVER BANK
maintains records in the normal course of its business that indicate the resi ults ofthat query. Based on my
review of the account records applicable to Cardmember(s), to the best of my knowledge
and belief the above
referenced Cardmember(s) is not engaged in any of the inilitary services of the United States.
I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge
.
CorgBetee Obi.
SUBSCRIBED TO AND SWORN TO before me this L day of _An S
oS. \ 2 2023.
Cah Cnc
ats Waa,
x eee
ee ,
RUBY
D coRDOVA
NOTARY PUBLIC-
ey MY COMMISSION EX
ee PIRES
“aE a a 8-23.25
SCB_WILLIAMS_1556225_1.2 vi2
BO Sco OVER
DISCOVER IT? CARD ENDINGINS267
i
CARDMEMBER SINCE 2018
ee nee os ~ oe a - - ae
bu any iy aL)
Previous Balance $6,062.33 New Balance Minimum Payment* Payment Due Date
Payments and Credits. $0.00
Purchases +$0.00 56,112.28 51,384.00 01/11/2022
Balance Transfers +$0.00. * Includes past due amount of $1211.00
Cash Advances +$0.00 Late Payment Warming: ff we de aot receive your minimu
Fees Charged m payment by the date
+$0.00 listed above, you may have to pay late fee of up to $40.00,
interest Charged +849.95 Minimum Payment Warning: if you make on} 'y the minimu
m payment each period,
you will pi ay More in interest and it will take longerta pay off
New Balance: $6,112.28 your balance.
For
exampt
See Interest Charge Calculationsection Following the Fees and
Interest Charged section for detailedAPR information fi 0 Lec
Credit Line charges. his inceshi ‘thi iE. lated
$5,500
Credit Line Available $0 on st
Cash Advance Credit Line $1,100
+ Only the min mun payment
sp
[ 24 years $23,960
a
Cash Advance Credit Line Available
$0 (you would tike information about credit ‘counseling services
, cali us at 1-800-347-1121,
- we
FICO? Score 8 based [on TransUnion® data:
AS OF 12/10/21
Updated tently
‘See Key Factors that help explain your score
arDiscaver.com or it aur mobile app
oma ss cements nn
Notice: Seereverse side for important information
Gait}
ACCOUNT HUMBER ENDING IN 9267
Detach at ove and return with
Discover. Do not fold, clip, staple or send cash,check payableto New Balance 56,112.28
Minimum Payment Due
$4,384.00
Uibeadad= tse ME a da dpe hahah tye Payment Due Date
01/11/2022
13
Es
CORA WILLIAMS
14 CLOVER ST Fora faster, easier Discover.com 1-800-347-2683 !
MIDDLETOWN CT 06457-5219 wayto pay...
See reverse forpayment eutofttioes, |
PO BOX 70176
PHILADELPHIA PA 19176-0176
New address, ema
or it
phone? Please update on reverse. mebbtat tet tala telaale
7a ae ee D
DISCOVER IT® CARD ENDING IN9267
CORA WILUAMS: Page 2 af 4
OPEN 70 CLOSE DATE: 11/17/2022 - 12/16/2024
Impartant Information
‘See yourCardmemberAge feoment. Your Cardmembey Agreement cantain isinimium Payment Due, (iii) statement Mini num Peyme
ntDue
terms of yaurAccount,
gall the amount, er (iy). other dollaramou at. IFyourscheduled “Other plus a fixed dollar
paymentis not enough to covert! ihe Minimum Paymi ent Due as dollar amount”
fisted on yourmoniinly
Lost or Stolen Cards. Report iimediately!
Call 1-800-347-2683, billing statement, your scheduled payment forthat month will be incteased ta cover
the Minimum Pay! meat Due. |fthe schedul led paymentis greaterthan the
PaymentDue, any excess Minimum
Agreement. your schedulwill be applied in accordance
What Yo Do if You Think You Find A Mistake On Your: Stateme with your Cardmember
an error an your statement, write to-us at Discover, PO Bax 30421,
nt: Ifyou think there is
Saltlake City, UT
ed payments ‘Bfeater tial in the New Balanceon yourbilling
84330-0621, ar submit the form provided at hitps: i /{discover.com/billingerrornotice, statement, that payment: will de processed only for tfhe amountof your New Balance,
‘You.must contact us within 60 days after the error. Your automatic payment: ‘amoumay
appeared an yaut statement.You ntbe less than the amount indicated an the billing
may callus, butit you do we ar 2 Hot required to investigat any potential
e errors, and
staiementbased on cred its or payments after the Closa Date.
you may have to pay the amou tin question. The Ifyou ento by ll
phone in aurautomatic paymi ent Service,
explains your dgbts, Please see jour Cardmember Billing Rights Notice further
blanks below and retain the authorizat ion for yourrecords,pleaseTfil-ithe
n following
hlinss/ fdiscaver.com/biliingrig H ts fora copy af ihisAgreem ent or visit,
Notice,
Payments. You mi payallor part of ‘our Account balance at any
Amount
must pay atleast hs 12 Minimum Paymet nt Due by the Paymen Due
time, However, you
t Date, Send an y rut pay Omin Pay
your alletwatsle form af payment (Pay: nent") and the bottom por of tio
this statemen
n t CiMin Pays§, CotherAmount §
inthe envetone provided, after affixi ing postage. Payments sent without proper
postag be retumed
ewi to ll
the send er \ryau pay by check, you authorizeus to use
Bank Routing #
Bark Account #,
information on your
the financialinstituticncheckindicate
to make an el lectronicfund transfer from youtaccountat
d an yo ur check orta process the paymentas a check Monthly on the OPaymentSue Date, or ©) Day of the month (INSERTDATE)
fransaction.ifa Paymentis processed asan electroni c fund transfer, the transfer will
be forthe amount ofthe check, funds: may bewithdraven from Credit Reparting, Credit Reportin . We may repart info rmationabout your
gs sed payments, orether defaults on-yourAccaunt
may be tellected in yourcredit renni a iort.
asthe same day we recelve your chec k, and you will not receiveyouraccountas soon
credit bureaus; Late payments,. to
your check back. Account
Please do not send cash. Sending cash is not allows ed. The processing We normallyzepart the status and payment
allowable form of Payme: nit maybe delayed of your
if you s: end cash or correspondence with
historyof your Account to credit12}
ourrepartis inaccurate orincompt porting agencies each month, ffyou believe that
your Payments, Ifyou send the Paymentto any ath eraddress, ete, please write us at this address: Discover,
Box 30939, Salt Lake City, UT 84130-0: PO
eavelopeniher than the one provi ‘ded. Payments received at! arifyou use an 939, Piwase include your name, address,
ly 5PM local time on any day will be creditedta yourAccaunt ‘our processing facility
home telephone numand ber Account number,
Payments teceived at our process’ ing facility after SPM local tas ofthat day. Paying Interest. Your due date is at least2: 5 daysafterthe
yourAccount as ofthe next day, Kyau have mispiaced your time will be credited to close
{at teast 23 days for billiny ig periods that beyin in February). Wewillof cach billing period
Paymentto Discaver, PO Box 611 03, Carol Stream, 1 60197-6envelope, send your int terest on Cash Advances and Balance Transl fersas of the later bogin charging
days fordeliv If yourFay
ery. mea ntis returned unpaid,we reserve 103, Please aliow 7-10
the rightta resubmit Date or the first day of the billing peried in whi ich the Iransact ofthe Transactlan