Complaint,Petition: AMERICAN EXPRESS NATIONAL BANK VS THOMAS BEETON

• 
• 

						
                                
Preview
                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/04/2019 10:57 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Castaneda,Deputy Clerk
                                                                                     19CHLC35359
                                       Assigned for all purposes to: Chatsworth Courthouse, Judicial Officer: Robert Schuit




              1     Christopher A. Beyer, State Bar #213264
                    Karen Etsell Lusis, State Bar #272739
              2     Camryn P. Berk, State Bar #317565
                    RAUSCH STURM
              3
                    3131 Camino Del Rio N., Suite 350
              4     San Diego, CA 92108
                    Telephone: (877) 215-2552
              5     Facsimile: (877) 396-4464
                    E-mail Address: LawfirmCA@rsieh.com
              6
                    Attorneys for Plaintiff
              7
              8                                      SUPERIOR COURT OF THE STATE OF CALIFORNIA
              9
                                              COUNTY OF LOS ANGELES, CHATSWORTH COURTHOUSE
            10
            11        American Express National Bank,                                                         )     Case No.:
                                                                                                              )
            12                                         Plaintiff,                                             )     COMPLAINT FOR:
                                                                                                              )     1. ACCOUNT STATED
            13                  vs.                                                                           )
            14                                                                                                )
                      THOMAS BEETON;                                                                          )     PRAYER AMOUNT: $12,293.31
            15        and DOES 1 through 10, inclusive,                                                       )
                                                                                                              )     LIMITED CIVIL CASE
            16                                    Defendants.                                                 )
            17                                                                                                )

            18             Plaintiff American Express National Bank (“Plaintiff”) alleges the following facts as to all causes of
            19      action as follows:
            20
                           1. Plaintiff is qualified to do business in California.
            21
                           2. This Court is proper for this action because Plaintiff is informed and believes that Defendant
            22
            23      THOMAS BEETON is a resident within the jurisdictional boundaries of this Court.

            24             3. Plaintiff is informed and believes that Defendant THOMAS BEETON and Defendants sued by the
            25      fictitious names DOES 1 through 10 (“Defendants”) are responsible for the alleged debt; however, Plaintiff
            26
                    is unaware of the true names and capacities of DOES 1 through 10 and will seek leave of this Court to
            27
                    amend this Complaint when the true names and capacities have been ascertained.
            28


                                                                                                   1
                                                                                              COMPLAINT                                                                    3830163