Complaint,Petition: DISCOVER BANK v. TARASOV, NICHOLAS

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                                RET:        SEPTEMBER         23,2014                                 SUPERIOR       COURT

DISCOVER           BANK   —

                                                                      JD    OF LITCHFIELD
vs.                                                               t   AT    LITCHFIELD

NICHOLAS           TARASOV                                            Opdey 25,2014
                                            COMPLAINT                 %g'%
Count        I    (Default       on     Credit        Account)

1      On    or before APRIL 30,2014,                       the defendant           became indebted
       to    the plaintiff in the sum                       of $13,108.41           for use
       of    credit       account           number      #HH#H#HHHHHHH2578
       issued       by    the    plaintiff.

       Despite       demand,          the     balance       of    $13,108.41         remains
       wholly unpaid and the defendant failed                                 and    continues
       to fail to make payment in full.

       The       Plaintiff       requests            that   no   post-judgment            interest     be
       awarded.

count        II    (Account          Stated)

4      Plaintiff          hereby incorporates paragraphs                           1-3    of   Count   I
       as though          set forth in full herein.

       The       defendant had              a credit account with the plaintiff,
       and       in connection              with that account,  plaintiff mailed,
       delivered,             sent     or    otherwise       transmitted           periodic
       account        statements             to   the    defendant         setting       forth   all   of
       the charges and credits                        applicable       to    the    account,      as   well
       as the balance due.

       Upon information and belief,   the defendant received and held
       these  statements for an unreasonabl e time with no known
       protest or known notice of defects to the plaintiff as to
       the charges and amounts due.

       The       final    statement         transmitted to the defendant, indicating
       a balance          due        and owing, was accepted and held by the
       defendant          for        an unreasonable time without protest or notice
       of    defect.
8   The plaintiff seeks damages for the account                             stated balance
    minus any credit(s) on the account occuring                             after the
    last statement was transmitted.



NOTICE      IS     HEREBY       GIVEN      to    the     defendant     that    the    plaintiff

intends      to        seek    satisfaction         of     any      judgment         endered    in

plaintiff's            favor   in   this   action      from   any    debt    accruing    to    the

defendant         by     reason      of    the    defendant's          personal       services.
STATEMENT   OF   AMOUNT   IN   DEMAND

The amount,   legal interest, or property in
demand,  exclusive of interest and costs,   is
greater than $5,000.00 but less than $15,000.00
The remedy sought is based upon an express      or
implied promise to pay a definite sum.
THE    PLAINTIFF       CLAIMS:

1.     Money    damages;      and

2      Costs    of    suit.




Dated    at    East    Hartford,       Connecticut Que                 2014   .



                              Holly     R.       Nelen,  Esq.
                              Law     Offices       Howard Lee     Schiff,    B.C
                              Juris No,           419040
                              510 Tolland           Street
                              POB 280245
                              E Hartford           cT     06128-0245
                              (860)     528-9991



THIS    COMMUNICATION         IS    FROM     A    DEBT    COLLECTOR.

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CN-¥25256