On September 21, 2021 a
Complaint,Petition
was filed
involving a dispute between
Discover Bank,
and
Sanchez-Aldana, Adriana A,
for Contract - Consumer/Commercial/Debt
in the District Court of Fort Bend County.
Preview
Filed
9/21/2021 2:42 PM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Donald Evans
21-DCV-287547
__
DISCOVER BANK, IN THE DISTRICT COURT
Plaintiff § Fort Bend County - 458th Judicial District Court
Vv. § JUDICIAL DISTRICT
ADRIANA A SANCHEZ-ALDANA, § FORT BEND COUNTY, TEXAS
§
Defendant(s) §
PLAINTIFF’S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
DISCOVER BANK, (“Plaintiff”), complains of ADRIANA A SANCHEZ-ALDANA,
(“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 Plaintiffis 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.
Plaintiff is a FDIC-insured Delaware State Bank. Plaintiff may be contacted through the
undersigned attorney.
DISCOVER BANK V. ADRIANA A SANCHEZ-ALDANA
Plaintiff's Original Petition
Defendant(s) is/are a resident(s) of FORT BEND County, Texas, and may be served with
process at 3603 TIMOTHY LN, RICHMOND, TX 77406. 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
Defendant(s) obtained a credit account from Plaintiff. The credit account is identified as
ending in account number
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.
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 $8,888.49. 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.
All conditions precedent to Plaintiff's right to bring suit on its claims have been
performed or have occurred.
DISCOVER BANK V. ADRIANA A SANCHEZ-ALDANA
Plaintiff's Original Petition
Wherefore, Plaintiff demands judgment in the amount of $8,888.49 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
Attorneys for Plaintiff
14090 SW FREEWAY, SUITE 408
SUGAR LAND, TX 77478
TEL: (281)494-0300
FAX: (281)494-0213
EMAIL: ZATE_LITIGATION@ZWICKERPC.COM
BY: Qaemire Cooks
[| | JOHNETTA LANG, ESQ.
State Bar Number 24036943
| | CHIDI A. OHA, ESQ.
State Bar Number 24094877
i[ | MEGAN
JASMINE COOKS, ESQ.
te Bar Number 24089624
FOY, ESQ.
State Bar Number 24120390
[| ] TABITHA HAYNES, ESQ.
State Bar Number 24118986
DISCOVER BANK V. ADRIANA A SANCHEZ-ALDANA
Plaintiff's Original Petition
Preview
Filed 9/21/2021 2:42 PM Beverley McGrew Walker District Clerk Fort Bend County, Texas Donald Evans 21-DCV-287547 __ DISCOVER BANK, IN THE DISTRICT COURT Plaintiff § Fort Bend County - 458th Judicial District Court Vv. § JUDICIAL DISTRICT ADRIANA A SANCHEZ-ALDANA, § FORT BEND COUNTY, TEXAS § Defendant(s) § PLAINTIFF’S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: DISCOVER BANK, (“Plaintiff”), complains of ADRIANA A SANCHEZ-ALDANA, (“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 Plaintiffis 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. Plaintiff is a FDIC-insured Delaware State Bank. Plaintiff may be contacted through the undersigned attorney. DISCOVER BANK V. ADRIANA A SANCHEZ-ALDANA Plaintiff's Original Petition Defendant(s) is/are a resident(s) of FORT BEND County, Texas, and may be served with process at 3603 TIMOTHY LN, RICHMOND, TX 77406. 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 Defendant(s) obtained a credit account from Plaintiff. The credit account is identified as ending in account number 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. 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 $8,888.49. 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. All conditions precedent to Plaintiff's right to bring suit on its claims have been performed or have occurred. DISCOVER BANK V. ADRIANA A SANCHEZ-ALDANA Plaintiff's Original Petition Wherefore, Plaintiff demands judgment in the amount of $8,888.49 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 Attorneys for Plaintiff 14090 SW FREEWAY, SUITE 408 SUGAR LAND, TX 77478 TEL: (281)494-0300 FAX: (281)494-0213 EMAIL: ZATE_LITIGATION@ZWICKERPC.COM BY: Qaemire Cooks [| | JOHNETTA LANG, ESQ. State Bar Number 24036943 | | CHIDI A. OHA, ESQ. State Bar Number 24094877 i[ | MEGAN JASMINE COOKS, ESQ. te Bar Number 24089624 FOY, ESQ. State Bar Number 24120390 [| ] TABITHA HAYNES, ESQ. State Bar Number 24118986 DISCOVER BANK V. ADRIANA A SANCHEZ-ALDANA Plaintiff's Original Petition