COMPLAINT

On September 30, 2015 a contracts and indebtedness - county case was filed by Discover Bank, represented by James G Downey, Iii, against Lacour, Celia M, in the jurisdiction of Pinellas County. Judge KELLY, LORRAINE presiding.

                        
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Case Number: 15-007498-CO Filing # 32686818 E-Filed 09/30/2015 03:59:45 PM. IN THE COUNTY COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA DISCOVER BANK, ) Plaintiff, ) CIVIL ACTION ) VS. ) ) CASE NO. CELIA M LACOUR, ) Defendant. ) / COMPLAINT FOR MONEY OWED Plaintiff, Discover Bank, sues Defendant CELIA M LACOUR and alleges: JURISDICTIONAL AND FACTUAL ALLEGATIONS 1. This is an action for money damages that exceed $5,000.00 but do not exceed $15,000.00, exclusive of court costs, for default under a credit account between Plaintiff and Defendant. 2. The Plaintiff is a corporate entity transacting business by and through the instrumentality of interstate commerce by the issuance of credit and is entitled to prosecute this civil action under the laws of the State of Florida. Plaintiff is the owner of the subject account for credit and is entitled to all sums due pursuant to the terms and conditions of the credit agreement. 3. Upon information and belief…

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