Motion for Writ in DISCOVER BANK vs. NATHANIEL STALLWORTH| Trellis.Law

On March 14, 2024 a Summons was filed involving a dispute between Discover Bank, and Nathaniel Stallworth, for SF in the District Court of Cuyahoga County.

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NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113

Court of Common Pleas

New Case Electronically Filed: COMPLAINT
March 14, 2024 09:24

By: DAVID MULLEN 0089053
Confirmation Nbr. 3113361

DISCOVER BANK CV 24 994383

Judge: SHIRLEY STRICKLAND SAFFOLD
NATHANIEL STALLWORTH

Pages Filed: 14

Electronically Filed 03/14/2024 09:24 / / CV 24 994383 / Confirmation Nbr. 3113361 / CLAJB
IN THE CUYAHOGA COUNTY COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OH
DISCOVER BANK
6500 NEW ALBANY ROAD EAST
NEW ALBANY, OH 43054
PLAINTIFF CASE NO.:
vs. JUDGE:

NATHANIEL STALLWORTH
3606 CONCORD DR
BEACHWOOD OH 44122-6015
DEFENDANT(S)

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-0205 (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 $6,635.32. 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 $6,635.32, plus post-judgment interest on the balance at the statutory rate from the date of

judgment and court costs.

Respectfully submitted,

DISCOVER BANK

/V 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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CM.TL28K.LIN.0620

DISCOVER CARDMEMBER AGREEMENT
Thank you for choosing Discover® card. This Agreement explains the current terms and conditions of your Account. The enclosed Pricing Schedule is part of this Agreement. Please read this Agreement, including

the Pricing Schedule, carefully. Keep them for your records. Contact us ifyou have any questions. We have included a"Definitions" section for your reference on page 3.

ACCEPTANCE OF AGREEMENT

You accept this Agreement ifyou do not cancel your Account within 30 days after receiving a Card. You also accept this Agreement if you or an Authorized User use the

Account. You may, however, reject the "Arbitration of Disputes" section as explained in that section.

CHANGES TO YOUR AGREEMENT

The rates, fees and terms of this Agreement may change from time to time. We may add or deleteany term to this Agreement. If required by law, we will give you advance

written notice of the change(s) and a right to reject the change(s). We will not charge any fee or interest charge prohibited by law.

USING YOUR ACCOUNT

Permitted Uses You may use your Account for Purchases, Balance Transfers and Cash Advances. You may not use it for illegal transactions.

Authorized Users You may request additional Cards for Authorized Users to make transactions on your Account. You must notify us ifyou wish to cancel the authority of an Authorized User

to use your Account. You are responsible for all charges made by your Authorized Users.

Joint Accounts If your Account is a joint Account

• each of you agrees to be liable individually and jointly for the entire amount owed on the Account; and

• any notice we mail to an address provided by either of you for the Account will serve as notice to both of you.

Checks If we provide you with Checks, we will tell you whether we will treat the Check as a Purchase, Balance Transfer or Cash Advance. You may not use these Checks to pay any

amount you owe us.

Credit Authorizations We may not authorize a transaction for security or other reasons. We will not be liable to you if we decline to authorize a transaction or if anyone refuses your Card, Check

or Account number.

Credit Lines We will tell you what your Account credit line is. You must keep your Account for Cash Advances. We may increase or decrease your Account credit line or your

balance below your Account credit line. If you do not, we may request immediate Cash Advance credit line without notice. We may delay increasing your available

payment of the amount by which you exceed it. We may establish a lower credit line credit by the amount of any payment that we receive for up to 10 business days.

FEES (See your Pricing Schedule for Additional Fees)

Late Fee We will not charge a Late Fee the first time you do not make the Minimum Payment were not charged a Late Fee during any of the prior six billing periods. Otherwise,

Due by the Payment Due Date. After that, ifyou do not pay the Minimum Payment the fee is $40. This fee will never exceed the Minimum Payment Due that was due

Due by the Payment Due Date, we will charge you a Late Fee. The fee is $29, if you immediately prior to the date on which the fee was assessed.

Returned Payment Fee If you make a payment that is not honored by your financial institution, we will any of the prior six billing periods. Otherwise, the fee is $40. This fee will never

charge you a Returned Payment Fee even if the payment is honored after we re- exceed the Minimum Payment Due that was due immediately prior to the date on

submit it. The fee is $29 if you were not charged a Returned Payment Fee during which the payment was returned to us

ANNUAL PERCENTAGE RATES ("APRS") (See your Pricing Schedule for the APRs that apply to your Account)

Variable APRs Your Pricing Schedule may include variable APRs. These APRs are determined by will take effect on the first day of the billing period that begins during the same

adding the number of percentage points that we specify to the Prime Rate. Variable calendar month that the Prime Rate changes. An increase in the APR will increase

APRs will increase or decrease when the Prime Rate changes. The APR change your interest charges and may increase your Minimum Payment Due.

Penalty APR None

MAKING PAYMENTS

Payment Instructions • You must pay in U.S. dollars. Please do not send cash. Sending cash is not • We credit your payments in accordance with the terms contained on your

allowed. All checks must be drawn on funds on deposit in the U.S. billing statement.

• You must pay us for all amounts due on your Account. This includes charges made • If you mail your payment to an address other than the address designated on your

by Authorized Users. billing statement, there may be a delay in processing and crediting the payment

• We may refuse to accept a payment in a foreign currency. If we do accept it, to your Account.

we will charge your Account our cost to convert it to U.S. dollars. • If a third party makes a payment on your Account and we return all or a part of

• We can accept late payments, partial payments or payments marked such payment, then we may adjust your Account for any amount returned. We
reserve the right to defend ourselves against any demand to return funds we
"payment in full" or with any other restrictive endorsement without
have received, and may agree to a compromise of the demanded amount as part
losing any of our rights under this Agreement.
of a settlement.

Minimum Payment Due You may pay the entire New Balance shown on your billing statement at any for any debt protection product that you enrolled in on or after 2/1/2015; Interest

time. Each billing period you must pay at least the Minimum Payment Due by the Charges; and Late Fees.

Payment Due Date shown on your billing statement. The Minimum Payment Due The Minimum Payment Due may also include amounts by which you exceed
will be any amount past due plus the greater of: your Account credit line. However, it will never exceed the New Balance. When

• $35; or we calculate the Minimum Payment Due, we may subtract from the New Balance

• 2% of the New Balance shown on your billing statement; or certain fees added to your Account during the billing period. The Minimum Payment

Due is rounded up to the nearest dollar.
• $20, plus any of the following charges as shown on your billing statement: fees

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MAKING PAYMENTS

How We Apply Payments We apply payments and credits at our discretion, including in a manner most Each billing period, we will generally apply amounts you pay that exceed the

favorable or convenient for us. In all cases, we will apply payments and credits as Minimum Payment Due to balances with higher APRs before balances with lower

required by applicable law. APRs as of the date we credit your payment.

INTEREST CHARGES

How We Calculate Interest We calculate interest charges each billing period by first figuring the "daily • We makeother adjustments (includingthose adjustmentsrequired in the "Paying
Charges—Daily Balance balance” for each Transaction Category. Transaction Categories include standard Interest" section).
Method (including current
Purchases, standard Cash Advances and different promotional balances, such as How We Figure Your Total Interest Charges
transactions}
Balance Transfers. • yye multiply the daily balance for each Transaction Category by its daily periodic

How We Figure the Daily Balance for Each Transaction Category rate. We do this for each day in the billing period. This gives us the interest charges
• We start with the beginning balance for each day. The beginning balance for for each Transaction Category. Tbget a daily periodic rate, we dividethe AP
the first day of the billing period is your balance on the last day of your previous applies to the Transaction Category by 365.
billing period *We UPa" tt1® interest charges. The sum is the total interest charge for
• We add any interest charges accrued on the previous day's daily balance and any ^e billing period.

new transactions and fees. We add any new transactions or fees as of the later of How We Include Fees
the Transaction Date or thefirst day of the billing period in which the transaction We add Balance Transfer Fees to the applicable Balance Transfer Transaction
or fee posted to your Account. Category. We add Cash Advance Fees to the applicable Cash Advance Transaction

• We subtract any new credits and payments. Category. We add all other fees to the standard Purchase Transaction Category.

Paying Interest When Interest Charges Begin New Purchases. New Purchases are Purchases that first appear on the next billing
We begin to impose interest charges on a transaction, fee or interest charge from statement. Interest will continue to accrue each day on Purchases that appeared on
the day we add it to the daily balance. We continue to impose interest charges previous billing statements until you pay the New Balance in full and will be billed
until you pay the total amount you owe us. You can avoid paying interest on ^e next billing cycle.

Purchases as described below. However, you cannot avoid paying interest on How We Apply Payments May Impact Your Grace Period
Balance Transfers or Cash Advances. |f y0U d0 not pay yOur Balance in full each month, then, depending on the

How to Avoid Paying Interest on Purchases ("Grace Period") balance to which we apply your payment, you may not get a grace period on
If you pay the New Balanceonyour current billing statement by the Payment Due new Purchases.

Date shown on that billing statement, we will not impose interest charges on

OTHER IMPORTANT INFORMATION

Default You are in default if: • you fail to comply with the terms of this Agreement or any Agreement with us or
• you file bankruptcy or another insolvency proceeding is filed by you or against you; an Affiliate, including failing to make a required payment when due, exceeding
, ............. , , ,, your Account credit line orusing your Card or Account for an illegal transaction.
• we have a reasonable belief that you are unable or unwilling to repay your
obligations to us; " You are in ^e'au't'we maY °eclare entire °f Y^r Account immediately
’....................... . . , due and payable without notice.
• you die or are legally declared incompetent or incapacitated;

Collection Costs If we use an attorney to collect your Account, we may charge you our legal costs as permitted by law. These include reasonable attorneys' fees, court or other collection costs,

and feesand costs of any appeal.

Merchant Disputes If you have a dispute with a merchant, you may request a credit to your Account. If we resolve the dispute in your favor, we will issue a credit to your Account. You assign to us

your claim for the credited amount against the merchant and/or any third party. At our request, you agree to provide this assignment in writing.

Automatic Account You may set up automatic billing or store your Account information with an Affiliate, Account information changes, which may include your billing address, you authorize us
Information Updates merchant, wallet provider, or other third party ("Permitted Party"). If you do, you to provide this updated information to any such Permitted Party at our discretion. You

authorize us to share your Account information, which may include your rewards must contact the Permitted Party directly or remove your credit card information from

account balance, with the Permitted Party, regarding the use of your Account. If your the Permitted Party website if you wish to stop automatic billing or Account updates.

Our Privacy Policy We send you our Privacy Policy when you open your Account and annually. • how we safeguard its confidentiality and security;

Contact us or visit Discover.com if you would like a copy. Please read it carefully. • when it may be shared with others; and

It summarizes: • how you can limit our sharing of this information.

• the personal information we collect;

Credit Reporting Agency You authorize us to get information from credit reporting agencies and other sources normally report to credit reporting agencies each month. If you believe that information

Information for servicing or review of your Account, collection and any other use permitted by law, we reported is inaccurate or incomplete, please write us at Discover, P.O. Box 30939,

includingto consideryou for otherproducts and services. We may reportthestatus and SaltlakeCity, UT84130-0939. Please includeyourname, address, home phonenumber

payment history of your Account to credit reporting agencies and other creditors. We and Account number.

Our Communications You agree that we, our Affiliates, and agents, including service providers (“Authorized You agree that the Authorized Parties may contact you using an automatic dialer or
with You Parties") may contact you, including calls, text message or email, about any current or pre-recorded voice message. If you no longer wish to be contacted on your cell phone

future accounts or applications, with respect to all products you have with us at any by an automated dialer or pre-recorded voice message, you must provide us written

phone number or email (i) you have provided to us, (ii) from which you contacted us, notice cancelling your consent at this address: Discover Bank, P.O. Box 30937, Salt Lake

or (iii) which weobtained and believe we can reach you at, even if your phone provider City, UT 84130-0937, The written notice must include: your name, mailing address,

may charge you message and data rates forcalls or texts. You agree that the Authorized the last four digits of yo ur Account number and the specific cell phone number(s) for

Parties may record or monitor any calls between you and the Authorized Parties. You which you would like to cancel your consent to be contacted by an automated dialer

agree to notify us if you change or discontinue using any phone number you provide, or pre-recorded voice message.

Unauthorized Use You must notify us immediately if: • you believe someone is using your Account or a Card without your permission.

• your Card is lost or stolen; or
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Cancellation of • You may cancel your Account. You will remain responsible for any amount you • We may cancel, suspend or not renew your Account at any time without notice.
Your Account owe us under this Agreement.

• Any joint Accountholder may cancel a joint Account. However, both of you will
remain responsible for paying all amounts owed.

OTHER IMPORTANT INFORMATION

Purchases and Cash Advances If you make a Purchase or Cash Advance in a foreign currency, we will convert depending on the country and currency in which the transaction is made. We

in Foreign Currencies it to U.S. dollars using a rate we choose. This rate will either be a government- use the rate in effect on the conversion date for the transaction. This rate may

mandated rate, a government-published rate or the interbank exchange rate, be different than the rate in effect on the Transaction Date for the transaction.

Governing Law This Agreement is governed by applicable federal law and by Delaware law. However, in the event you default and we file a lawsuit to recover funds loaned to you, the
statute of limitations of the state where the lawsuit is filed will apply, without regard to that state's conflicts of laws principles or its "borrowing statute."

Severability Except as set forth in the "Arbitration" section, if any partof this Agreement is found to be invalid, the rest of it will still remain in effect.

Enforcing this Agreement We may delay enforcing or not enforce any of our rights under this Agreement without losing or waiving any of them.

Assignment of Account We may sell, assign or transfer your Account or any portion of it without notice to you. You may not sell, assign or transfer your Account without first obtaining our prior

written consent.

MILITARY BORROWERS

Statement of MAPR Federal law provides important protections to members of the Armed Forces and credit transaction; (3) any application fee charged (other than certain application

their dependents relating to extensions of consumer credit. In general, the cost of fees for specified credit transactions or accounts); and (4) any participation fee

consumer credit to a member of the Armed Forces and his or her dependent may charged (other than certain participation fees for a credit card account). If you

not exceed an Annual Percentage Rate of 36 percent. This rate must include, as would like more information about whether this section applies to you, please

applicable to the credit transaction or account: (1) the costs associated with credit contact us at 1-844-DFS-4MIL (1-844-337-4645) anytime 24/7. If calling outside

insurance premiums; (2) fees for ancillary products sold in connection with the the U.S. you can contact us at +1 -801 -451 -3730.

Oral Disclosures Before agreeing to this Agreement, in order to hear important disclosures and payment information about this Agreement, please call 1 -844-D FS-4MIL (1-844-33 7-4645)
anytime 24/7. If calling outside the U.S. you can contact us at +1-801-451-3730.

Unless we tell you otherwise, you can notify us: • by phone at 1 -800-347-3085 or • in writing to Discover, P.O. Box 30943, Salt Lake City, UT 84130-0943.

When writing, please include your name, address, home phone number and Account number. You must contact us within 15 days after changing your email address, mailing address or phone number.

DEFINITIONS

"Account" means your Discover card account. "Check" means any check we send to you to access your Account.

"Affiliate" means our parent corporations, subsidiaries and affiliates. "Pricing Schedule" means the document entitled, "Pricing Schedule," which lists the APRs that
apply to your Account and other important information,
"Authorized User" means any person you authorize to use your Account or a Card, whether you
notify us or not. "Prime Rate" means the highest rate of interest listed as the U.S. Prime rate in the Money Rates

"Balance Transfer" means a balance transferred from another creditor to your Account. section of the online Wa// Street Journal (wwiv.ws/.com) on the last business day of the month.

"Card" means any one or more Discover cards issued to you or someone else with your authorization. "Purchase" means the use of your Account to purchase or lease goods or services at
participating merchants.
"Cash Advance" means the use of your Account for:
"We," "us" and "our" refer to Discover Bank, the issuer of your Card.
• obtaining cash from participating automated teller machines, financial institutions or other
"You," "your" or "yours" refer to you and any other person(s) who are also contractually liable
locations; and
under this Agreement.
• online gambling, or to purchase lottery tickets, money orders, casino chips, foreign currency or
"Transaction Date" means the date shown on your billing statement for a transaction or fee.
similar items.

ARBITRATION

Agreement to Arbitrate. In the event of a dispute between you This arbitration agreement does not apply if, on the date you relief. If acourt decidesthat applicable lawprecludesenforcementof

and us arising out of or relating to this Account or the relationships submit your Application or on the date we seek to invoke any of this paragraph's limitations as to a particular Claim for relief,

resulting from this Account or any other dispute between you or this arbitration agreement, you are a member of the Armed then after all appeals from that decision have been exhausted, that
Claim (and only that Claim) must be severed from the arbitration and
us, including, for example, a dispute based on a federal or state Forces or a dependent of such a member covered by the federal
may be brought in court. Only a court, and not an arbitrator, shall
statute or local ordinance ("Claim"), either you or we may choose Military Lending Act. If you would like more information
determine the validity, scope, and effect of the Class Action Waiver.
to resolve the Claim by binding arbitration, as described below, about whether you are covered by the Military Lending Act,

instead of in court. Any Claim (except for a Claim challenging the Your Right to Go To Small Claims Court. We will not choose
please contact us at 1-844-DFS-4MIL (1-844-337-4645) or
to arbitrate any individual Claim you bring in small Claims court
validity or enforceability of this arbitration agreement, including if you are calling from outside the U.S. at +1-801-451-373O.
or your state's equivalent court. However, if such a Claim is
the Class Action Waiver) may be resolved by binding arbitration CLASS ACTION WAIVER. ARBITRATION MUST BE ON AN
transferred, removed or appealed to a different court, we may
if either side requests it. THIS MEANS IF EITHER YOU OR WE INDIVIDUAL BASIS. THIS MEANS NEITHER YOU NOR WE MAY
JOIN OR CONSOLIDATE CLAIMS IN ARBITRATION BY OR then choose to arbitrate.
CHOOSE ARBITRATION, NEITHER PARTY WILL HAVE THE RIGHT TO

LITIGATE SUCH CLAIM IN COURT OR TO HAVE A JURY TRIAL. ALSO AGAINST OTHER CARDMEMBERS, OR LITIGATE IN COURT OR Governing Law and Rules, This arbitration agreement is
ARBITRATE ANY CLAIMS AS A REPRESENTATIVE OR MEMBER governed by the Federal Arbitration Act (“FAA"). Arbitration must
DISCOVERY AND APPEAL RIGHTS ARE LIMITED IN ARBITRATION.
OF A CLASS OR IN A PRIVATE ATTORNEY GENERAL CAPACITY.
Even if all parties have opted to litigate a Claim in court, you or proceed only with the American Arbitration Association ("AAA”).
The arbitrator may award injunctive relief only in favor of the The rules for the arbitration will be those in this arbitration
we may elect arbitration with respect to any Claim made by
individual party seeking relief and only to the extent necessary
agreement and the procedures of the AAA, but the rules in this
a new party or any new Claims later asserted in that lawsuit.
to provide relief warranted by that party's individual Claim. The
arbitration agreement will be followed if there is disagreement
arbitrator may not award class, representative or public injunctive

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ARBITRATION

between the agreement and the AAA's procedures. If the AAA's The arbitrator's decision will be final and binding except for any Other Beneficiaries of this Agreement. In addition to you and

procedures change after the Claim is filed, the procedures in effect review allowed by the FAA. However, if more than $100,000 was us, the rights and duties described in this arbitration agreement

when the Claim was filed will apply. genuinely in dispute, then either you or we may choose to appeal to apply to: our Affiliates and our and their officers, directors and
a new panel of three arbitrators. The appellate panel is completely employees; any third party co-defendant of a Claim subject to this
For a copy of the AAA's procedures, to file a Claim or for other
free to accept or reject the entire original award or any part of it. arbitration agreement; and all joint Accountholders and Authorized
information, please contact the AAA at 1101 Laurel Oak Rd.,
The appeal must be filed with AAA not later than 30 days after Users of your Account(s).
Voorhees, NJ 08043, www.adr.org (1-877-495-4185).
the original award issues. The appealing party pays all appellate Survival of this Agreement. This arbitration agreement shall
If the AAA is completely unavailable, and if you and we cannot
costs unless the appellate panel determines otherwise as part of survive:
agree on a substitute, then either you or we may request that a
its award.
• closing of your Account;
court with jurisdiction appoint a substitute
Claim Notice and Special Payment. If you have a Claim, before • voluntary payment of your Account or any part of it;
Fees and Costs. If you wish to begin arbitration against us but
initiating an arbitration proceeding, you may give us written notice
you cannot afford to pay the AAA's or arbitrator's costs, we will • any legal proceedings to collect money you owe;
of the Claim ("Claim Notice") at least 30 days before initiating the
advance those costs if you ask us in writing. Any request like this • any bankruptcy by you; and
arbitration proceeding. The Claim Notice must include your name,
should be sent to Discover, P.O. Box 30421, Salt Lake City, UT ♦ any sale by us of your Account.
address, and account number and explain in reasonable detail the
84130-0421. If you lose the arbitration, the arbitrator will decide You Have the Right to Reject Arbitration for this Account.
nature of the Claim and any supporting facts. Any Claim Notice shall
whether you must reimburse us for money we advanced for you You may reject the arbitration agreement but only if we
be sent to us at Discover, P.O. Box 794, Deerfield, IL 60015 (or such
for the arbitration. If you win the arbitration, we will not ask for
other address as we shall subsequently provide to you). If, and only receive from you a written notice of rejection within
reimbursement of money we advanced. Additionally, if you win the
if, (1) you submit a Claim Notice in accordance with this agreement 30 days of your receipt of the Card after your Account is
arbitration, the arbitrator may decide that you are entitled to be opened. You must send the notice of rejection to: Discover,
on your own behalf (and noton behalf of any other party); and (2)
reimbursed your reasonable attorneys1 fees and costs (if actually P.O. Box 30938, Salt Lake City, UT 84130-0938. Your rejection
an arbitrator, after finding in your favor in any respect on the merits
paid by you). notice must include your name, address, phone number, Account
of your Claim, issues you an award that (excluding any arbitration
Hearings and Decisions. Arbitration hearings will take place in fees or attorneys' fees and costs awarded by the arbitrator) is number and personal signature. No one else may sign the rejection
the federal judicial district where you live. A single arbitrator will greater than the value of Discover's last written settlement offer notice for you. Your rejection notice must not be sent with any
be appointed. The arbitrator must: made before an arbitrator was selected, then you will be entitled to other correspondence. Rejection of arbitration will not affect

• Follow all applicable substantive law, except when contradicted the amount of the award or $7,500, whichever isgreater. If you are your other rights or responsibilities under this Agreement. If

by the FAA; entitled to the $7,500, you will receive in addition any arbitration you reject arbitration, neither you nor we will be subject to the

fees or attorneys' fees and costs awarded by the arbitrator. arbitration agreement for this Account. Rejection of arbitration
• Follow applicable statutes of limitations;
for this Account will not constitute rejection of any prior or future
Any arbitration award may be enforced (such as through a
• Honor valid Claims of privilege;
arbitration agreement between you and us.
judgment) in any court with jurisdiction.
• Issue a written decision including the reasons for the award.

Your Billing Rights: After we finish our investigation, one of two things will happen:
• If we made a mistake: You will not have to pay the amount in question or any interest or other fees
Keep This Document For Future Use
related to that amount.
• If we do not believe there was a mistake: You will have to pay the amount in question, along with
This notice tells you about your rights and our responsibilities under the Fair Credit Billing Act.
applicable interest and fees. We will send you a statement of the amount you owe and the date
What To Do If You Find A Mistake On Your Statement
payment is due. We may then report you as delinquent if you do not pay the amount we think
If you think there is an error on your statement, write to us at:
you owe.
Discover
If you receive our explanation but still believe your bill is wrong, you must write to us (or visit
P.O. Box 30421
https://discover.com/billingerrornotice) within 10 days telling us that you still refuse to pay. If you do so,
Salt Lake City, UT 84130-0421.
we cannot report you as delinquent without also reporting that you are questioning your bill. We must tell
You may also contact us on the Web: https://discover.com/billingerromotice

Case Info

Judge

SHIRLEY STRICKLAND SAFFOLD Track Judge’s New Case

Case No.

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Document Filed Date

March 14, 2024

Case Filing Date

March 14, 2024

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Summons: DISCOVER BANK vs. NATHANIEL STALLWORTH

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