Complaint,Petition: AMERICAN EXPRESS NATIONAL BANK VS PASQUALE CASSALIA,AN INDIVIDUAL

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                                19SMCV01831
                                       Assigned for all purposes to: Santa Monica Courthouse, J udicial Officer: Elaine Mandel

Electronically FILED   Superior Court of California, County of Los Angeles on 10/17/2019 04:12 PM Sherri R. Carter, Executive Officer/Clerk of Court, by B. McClendon,Deputy   Clerk
                       Spencer Penuela, Esq. SBN: 324544
                       Kambrie L Keith, Esq. SBN: 303847
                       Henry Yandell, Esq. SBN: 321114
                       MICHAEL & ASSOCIATES, PC
                       555 St. Charles Drive, Suite 204
                       Thousand Oaks, California 91360
                       Telephone: (805) 379-8505
                       Facsimile: (805) 379-8525

                       Attorneys for Plaintiff,
                       American Express National Bank f/k/a
                       American Express Centurion Bank
                       Our File Number: 19114780


                                                 SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                               FOR THE COUNTY OF LOS ANGELES
                10                                                         UNLIMITED CIVIL CASE
                11     American Express National Bank f/k/a                                     )       CaseNo.:         195M C¥V01831
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                       American Express Centurion Bank,                                         )
                                                                                                        COMPLAINT FOR DAMAGES
                13                           Plaintiff,
                                                                                                         1    Common Counts: Book Account,
                14               VS.                                                                          Account Stated
                                                                                                         2.   Quantum Meruit-Reasonable Value
                15     Pasquale Cassalia, an individual; Does |
                16     through 20, inclusive.
                                                                                                        PRAYER AMOUNT:                  $34,009.78
                17                           Defendants.

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                                  Plaintiff alleges as follows:
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                                                                         GENERAL ALLEGATIONS
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                            1    At all times herein mentioned, Plaintiff, American Express National Bank f/k/a American
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                       Express Centurion Bank, (hereinafter "American Express"), is incorporated under United States
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                       law as a national bank, and is duly licensed and authorized to engage in business and is engaged
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                       in the doing of business by virtue of the laws and regulations of the State of California.
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                            2.   Plaintiff is informed and believes and thereon alleges that at all times mentioned herein,
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                       Defendant, Pasquale Cassalia, an individual (hereinafter "Pasquale Cassalia") is or was a resident
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                       of and living in the State of California, County of Los Angeles.
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                       Mt
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                                                                        COMPLAINT FOR DAMAGES