Exhibit,Appendix: Michael Celso v. Lyons Bancorp Inc, Lyons National Bank

On April 27, 2023 a Exhibit,Appendix was filed involving a dispute between Michael Celso, and Lyons Bancorp Inc, Lyons National Bank, for Commercial - Contract in the District Court of Wayne County.

Preview
FILED: WAYNE COUNTY CLERK 09/22/2023 04:59 PM INDEX NO. CV089534
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 09/22/2023

EXHIBIT
A
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WAYNE
---------------------------------------------------------------------X
MICHAEL CELSO, on behalf of
himself and all others similarly
situated,

Plaintiff,

-against-

LYONS BANCORP, INC. d/b/a Index No. ___________
THE LYONS NATIONAL BANK, JURY DEMAND

Defendant.
---------------------------------------------------------------------X

CLASS ACTION COMPLAINT

Plaintiff, Michael Celso, on behalf of himself and all others similarly situated, by and through

undersigned counsel, alleges:

INTRODUCTION

1. This is a civil action seeking monetary damages, restitution, and injunctive and

declaratory relief from Defendant, arising from its routine practices of assessing (1) Overdraft Fees

(“OD Fees”) on transactions that did not actually overdraw checking accounts and (2) OD Fees on

phantom transactions—where an accountholder never made a withdrawal request and where an

account balance was never reduced.

2. These practices breach promises made in Defendant’s adhesion contract with its

customers, attached hereto as Ex. A (the “Contract”).

3. Plaintiff and other customers of Defendant have been injured by Defendant’s

improper fee maximization practices. Plaintiff, individually and on behalf of the classes of

individuals preliminarily defined below, brings claims for Defendant’s breach of contract,

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including the duty of good faith and fair dealing, and/or unjust enrichment, and violation of New

York General Business Law § 349, et seq.

PARTIES

4. Plaintiff is a citizen and resident of Walworth, New York. He has maintained a

checking account with Defendant at all times relevant hereto.

5. Defendant is a bank with more than $1.7 billion in assets. Defendant maintains its

headquarters and principal place of business in Lyons, New York. Among other things, Defendant

is engaged in the business of providing retail banking services to consumers, including Plaintiff

and members of the Classes, in this district.

VENUE

6. Venue is proper in this District pursuant to New York Civil Law and Practice Law

§ 503(c) because Defendant’s principal place of business is in Wayne County, and the events or

omissions giving rise to the claims asserted herein occurred and continue to occur in Wayne

County.

I. BACKGROUND FACTS

7. Overdraft fees and insufficient funds fees (“NSF fees”) are among the primary fee

generators for banks. According to a banking industry market research company, Moebs Services,

in 2018 alone, banks generated an estimated $34.5 billion from overdraft fees. Overdraft Revenue

Inches Up in 2018, https://bit.ly/3cbHNKV.

8. Unfortunately, the customers who are assessed these fees are the most vulnerable

customers. Younger, lower-income, and non-white account holders are among those who were

more likely to be assessed overdraft fees. Overdrawn: Consumer Experiences with Overdraft, Pew

Charitable Trusts 8 (June 2014), https://bit.ly/3ksKD0I.

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9. Because of this, industry leaders like Bank of America, Capital One, Wells Fargo,

Alliant, and Ally have made plans to end the assessment of OD or NSF fees entirely. See Hugh

Son, Capital One to Drop Overdraft Fees for All Retail Banking Customers, NBC News (Dec. 1,

2021), https://nbcnews.to/3DKSu2R; Paul R. La Monica, Wells Fargo Ends Bounced Check Fees,

CNN (Jan. 12, 2022), https://bit.ly/3iTAN9k.

10. In line with this industry trend, the New York Attorney General recently asked other

industry leading banks to end the assessment of all OD Fees by the summer of 2022. NY Attorney

General asks banks to end overdraft fees, Elizabeth Dilts Marshall, Reuters (April 6, 2022).

11. Through the imposition of these fees, Defendant has made substantial revenue to

the tune of tens of millions of dollars, seeking to turn its customers’ financial struggles into

revenue.

II. DEFENDANT ASSESSES OD FEES ON TRANSACTIONS THAT DO NOT
OVERDRAW THE ACCOUNT

A. The Contract

12. The Contract states:

You understand that we may, at our discretion, honor withdrawal requests
that overdraw your account. However, the fact that we may honor withdrawal
requests that overdraw the account balance does not obligate us to do so later. So
you can NOT rely on us to pay overdrafts on your account regardless of how
frequently or under what circumstances we have paid overdrafts on your account
in the past.

[…]

You agree that we may charge fees for overdrafts, except for overdrafts
caused by ATM withdrawals or one-time debit card transactions if you have not
opted-in to that service . . . .

Ex. A at 3.

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13. In breach of this promise, Defendant assesses OD Fees when a “withdrawal

request” does not “overdraw” the “account.”

14. Because there is enough money in the account, no overdraft occurs. Yet, Defendant

charges an OD fee anyway.

B. Plaintiff’s Transactions

15. On April 30, 2021 Defendant charged Plaintiff a $36 fee on a purchase, even

though, according to Defendant’s own account statements, the balance in the account was positive

after the purchase. Indeed, even after Defendant assessed the $36 fee, Plaintiff’s account had a

positive balance of $23.87.

16. The improper fee charged by Defendant was not an error by Defendant, but rather

was an intentional charge made by Defendant as part of its standard processing of transactions.

17. Plaintiff therefore had no duty to report the fee as an error because it was not;

instead, it was part of the systematic, improper and intentional assessment of fees according to

Defendant’s standard practices.

18. Moreover, any such reporting would have been futile.

III. DEFENDANT ASSESSES OD FEES AND NSF FEES ON PHANTOM
TRANSACTIONS
A. Overview of the Claim

19. Plaintiff further brings this action challenging Defendant’s practice of charging OD

Fees and NSF Fees on phantom transactions—where accountholders never perform a debit or

transaction and where the account balance is never overdrawn.

20. Several apps and websites, including Square, Airbnb, PayPal, and others, use a

verification process to confirm the validity of a user’s bank account so that the user can then

seamlessly send and receive payments.

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21. As part of the account opening process, to verify a user’s bank account, these

entities will deposit and immediately withdraw a tiny amount, usually between one cent and nine

cents. This deposit and withdrawal process occurs virtually simultaneously and is designed solely

to ensure the account is valid and the entity can communicate with the account by sending and

then debiting a small amount to and from the account.

22. Importantly, no actual purchase or payment is involved, and there is no change to

the account balance.

23. This bank account linking and verification process is instantaneous. Yet, Defendant

splits this instantaneous process in order to increase fees it charges on accounts.

24. A bank like Defendant is notified and aware of this routine practice, just as it is

aware and notified that an accountholder has made no purchase, debit or transaction when third

parties merely verify a consumer’s account with this method.

25. Plaintiff signed up for an account with SmartPay Rewards, a service that allows

customers to save 10 cents per gallon on gas. SmartPay Rewards uses a service called ZipLine to

“validate[] [an] enrolled bank account information to ensure that [SmartPay Rewards] ha[s] the

correct account number.”1

26. ZipLine’s FAQ page states that it submits a deposit and withdrawal to a customer’s

bank account to confirm the validity of the account. Id.

27. On May 19, 2021, the ZipLine service put this verification process into motion,

with the sole and exclusive intent to verify that the Plaintiff’s account was valid and active. To do

this, it made an instantaneous deposit and withdrawal. No purchase or transaction was made by

the Plaintiff and no change to their account balance occurred.

1
See Zipline **FAQ** (https://secure.paymentcard.com/faq1.php).
6

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28. Nonetheless, Defendant charged Plaintiff a $36 OD Fee when it debited the

withdrawal had been deposited immediately prior.

29. As further examples, Defendant also charged OD Fees on a phantom transactions

on December 7, 2020 (validation from VENMO) and December 9, 2020 (validation from Square

Inc.).

30. These OD Fees assessment violated Defendant’s Contract.

IV. The Imposition of These Improper Fees Breaches Defendant’s Duty of Good Faith
and Fair Dealing.

31. Parties to a contract are required not only to adhere to the express conditions in the

contract, but also to act in good faith when they are invested with a discretionary power over the

other party. This creates an implied promise to act in accordance with the parties’ reasonable

expectations and means that Defendant is prohibited from exercising its discretion to enrich itself

and gouge its customers. Indeed, Defendant has a duty to honor payment requests in a way that is

fair to Plaintiff and its other customers and is prohibited from exercising its discretion to pile on

ever greater penalties on the depositor.

32. Here—in the adhesion agreements Defendant foisted on Plaintiff and its other

customers—Defendant has provided itself numerous discretionary powers affecting customers’

accounts. But instead of exercising that discretion in good faith and consistent with consumers’

reasonable expectations, Defendant abuses that discretion to take money out of consumers’

accounts without their permission and contrary to their reasonable expectations.

33. When Defendant charges these improper fees, it uses its discretion to define the

meaning of key terms in a way that violates common sense and reasonable consumer expectations.

Defendant uses its contractual discretion to define those terms to choose a meaning that directly

causes more fees.

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34. In addition, Defendant exercises its discretion in its own favor and to the prejudice

of Plaintiff and its other customers when assesses the improper fees as alleged herein. Further,

Defendant abuses the power it has over customers and their bank accounts and acts contrary to

their reasonable expectations under the Contract. This is a breach of Defendant’s duty to engage

in fair dealing and to act in good faith.

35. It was bad faith and totally outside of Plaintiff’s reasonable expectations for

Defendant to use its discretion to assess these improper fees.

CLASS ALLEGATIONS

36. Plaintiff brings this action on behalf of himself and all others similarly situated

pursuant to NY CPLR § 901 on behalf of the following Class.

37. The proposed Class is defined as:

The Overdraft Fee Class: All accountholders who, during the
applicable statute of limitations, were Defendant checking account
holders and were charged overdraft fees on transactions that did not
overdraw their checking.

The Phantom Transactions Class: All accountholders who, during
the applicable statute of limitations, were Defendant checking
account holders and were charged an overdraft fee or an NSF fee as
a result of a verification process on their accounts that resulted in no
change to their account balances.

38. Plaintiff reserves the right to modify or amend the definition of the proposed

Classes before the Court determines whether certification is appropriate.

39. Excluded from the Classes are Defendant, its parents, subsidiaries, affiliates,

officers, directors, legal representatives, successors, and assigns; any entity in which Defendant

has a controlling interest; all customers members who make a timely election to be excluded;

governmental entities; and all judges assigned to hear any aspect of this litigation, as well as their

immediate family members.

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40. The time period for the Classes is the number of years immediately preceding the

date on which this Complaint was filed as allowed by the applicable statute of limitations, going

forward into the future until such time as Defendant remedies the conduct complained of herein.

41. Numerosity. The members of the Classes are so numerous that joinder is

impractical. The Classes consist of thousands of members, the identities of whom are within the

exclusive knowledge of Defendant and can be readily ascertained only by resort to Defendant’s

records.

42. Typicality. The claims of the representative Plaintiff are typical of the claims of the

Classes in that the representative Plaintiff, like all members of the Classes, has been damaged by

Defendant’s misconduct in that he has been assessed unlawful overdraft fees. Furthermore, the

factual basis of Defendant’s misconduct is common to all members of the Classes and represents

a common thread of unlawful and unauthorized conduct resulting in injury to all members of the

Classes. Plaintiff has suffered the harm alleged and has no interests antagonistic to the interests of

any other members of the Classes.

36. Commonality. There are numerous questions of law and fact common to the Classes

and those common questions predominate over any questions affecting only individual members

of the Classes.

37. Among the questions of law and fact common to the Classes include:

a. Whether Defendant imposed OD Fees on transactions that did not overdraw
checking accounts;

b. Whether Defendant imposed OD Fees and/or NSF Fees on phantom
transactions;

c. Whether these practices breach the Contract;

d. Whether Defendant breached its covenant of good faith and fair dealing through
its fee policies and practices as described herein;

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e. Whether Defendant was unjustly enriched as a result of these fee assessment
practices;

f. Whether Defendant violated the New York General Business Law § 349, et
seq.;

g. The proper method or methods by which to measure damages; and

h. The declaratory and injunctive relief to which the Classes are entitled.

38. Plaintiff is committed to the vigorous prosecution of this action and has retained

competent counsel experienced in the prosecution of class actions, particularly on behalf of

consumers and against financial institutions. Accordingly, Plaintiff is an adequate representative

and will fairly and adequately protect the interests of the Classes.

39. Superiority. A class action is superior to other available methods for the fair and

efficient adjudication of this controversy. Since the amount of each individual class member’s

claim is small relative to the complexity of the litigation, no class member could afford to seek

legal redress individually for the claims alleged herein. Therefore, absent a class action, the

members of the Classes will continue to suffer losses and Defendant’s misconduct will proceed

without remedy.

40. Even if class members themselves could afford such individual litigation, the court

system could not. Given the complex legal and factual issues involved, individualized litigation

would significantly increase the delay and expense to all parties and to the Court. Individualized

litigation would also create the potential for inconsistent or contradictory rulings. By contrast, a

class action presents far fewer management difficulties, allows for the consideration of claims

which might otherwise go unheard because of the relative expense of bringing individual lawsuits,

and provides the benefits of adjudication, economies of scale, and comprehensive supervision by

a single court.

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41. Plaintiff suffers a substantial risk of repeated injury in the future. Plaintiff, like all

Class members, is at risk of additional improper fees. Plaintiff and the Class members are entitled

to injunctive and declaratory relief as a result of the conduct complained of herein. Money damages

alone could not afford adequate and complete relief, and injunctive relief is necessary to restrain

Defendant from continuing to commit its unfair and illegal actions.

CAUSE OF ACTION ONE
Breach of Contract, Including Breach of the Covenant of
Good Faith and Fair Dealing
(On Behalf of Plaintiff and the Overdraft Fee Class)

42. Plaintiff realleges and incorporates by reference all the foregoing allegations as if

they were fully set forth herein.

43. Plaintiff and Defendant have contracted for bank account services, as embodied in

the Contract.

44. All contracts entered by Plaintiff and the Overdraft Fee Class are identical or

substantively identical because Defendant’s form contracts were used uniformly.

45. Defendant has breached the express terms of its own agreements as described

herein.

46. Under New York law, good faith is an element of every contract between financial

institutions and their customers because banks and credit unions are inherently in a superior

position to their checking account holders and, from this superior vantage point, they offer

customers contracts of adhesion, often with terms not readily discernible to a layperson.

47. Good faith and fair dealing means preserving the spirit—not merely the letter—of

the bargain. Put differently, the parties to a contract are mutually obligated to comply with the

substance of their contract in addition to its form. Evading the spirit of the bargain and abusing the

power to specify terms constitute examples of bad faith in the performance of contracts.

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48. Subterfuge and evasion violate the obligation of good faith in performance even

when an actor believes their conduct to be justified. Bad faith may be overt or may consist of

inaction, and fair dealing may require more than honesty. Examples of bad faith are evasion of the

spirit of the bargain and abuse of a power to specify terms.

49. Defendant abused the discretion it granted to itself when it charged fees when

transactions did not overdraw checking accounts.

50. Defendant also abused the discretion it granted to itself by defining key terms in a

manner that is contrary to reasonable account holders’ expectations.

51. In these and other ways, Defendant violated its duty of good faith and fair dealing.

52. Defendant willfully engaged in the foregoing conduct for the purpose of (1) gaining

unwarranted contractual and legal advantages; and (2) unfairly and unconscionably maximizing

fee revenue from Plaintiff and other members of the Class.

53. Plaintiff and members of the Class have performed all, or substantially all, of the

obligations imposed on them under the agreements.

54. Plaintiff and members of the Class have sustained damages as a result of

Defendant’s breaches of contract, including breaches of contract through violations of the covenant

of good faith and fair dealing.

55. Plaintiff and the members of the Class are entitled to injunctive relief to prevent

Defendant from continuing to engage in the foregoing conduct.

CAUSE OF ACTION TWO
Breach of Contract, Including Breach of the Covenant of Good Faith and Fair Dealing
(On Behalf of Plaintiff and the Phantom Transaction Class)

56. Plaintiff realleges and incorporates by reference all the foregoing allegations as if

they were fully set forth herein.

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57. Plaintiff and Defendant have contracted for bank account services, as embodied in

the Contract.

58. All contracts entered by Plaintiff and the Overdraft Fee Class are identical or

substantively identical because Defendant’s form contracts were used uniformly.

59. Defendant has breached the express terms of its own agreements as described

herein.

60. Under New York law, good faith is an element of every contract between financial

institutions and their customers because banks and credit unions are inherently in a superior

position to their checking account holders and, from this superior vantage point, they offer

customers contracts of adhesion, often with terms not readily discernible to a layperson.

61. Good faith and fair dealing means preserving the spirit—not merely the letter—of

the bargain. Put differently, the parties to a contract are mutually obligated to comply with the

substance of their contract in addition to its form. Evading the spirit of the bargain and abusing the

power to specify terms constitute examples of bad faith in the performance of contracts.

62. Subterfuge and evasion violate the obligation of good faith in performance even

when an actor believes their conduct to be justified. Bad faith may be overt or may consist of

inaction, and fair dealing may require more than honesty. Examples of bad faith are evasion of the

spirit of the bargain and abuse of a power to specify terms.

63. Defendant abused the discretion it granted to itself when it charged fees on phantom

transactions.

64. Defendant also abused the discretion it granted to itself by defining key terms in a

manner that is contrary to reasonable account holders’ expectations.

65. In these and other ways, Defendant violated its duty of good faith and fair dealing.

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66. Defendant willfully engaged in the foregoing conduct for the purpose of (1) gaining

unwarranted contractual and legal advantages; and (2) unfairly and unconscionably maximizing

fee revenue from Plaintiff and other members of the Class.

67. Plaintiff and members of the Class have performed all, or substantially all, of the

obligations imposed on them under the agreements.

68. Plaintiff and members of the Class have sustained damages as a result of

Defendant’s breaches of contract, including breaches of contract through violations of the covenant

of good faith and fair dealing.

69. Plaintiff and the members of the Class are entitled to injunctive relief to prevent

Defendant from continuing to engage in the foregoing conduct.

CAUSE OF ACTION THREE
Unjust Enrichment
(On behalf of Plaintiff and the Classes)

70. Plaintiff incorporates the preceding paragraphs of this Complaint as if fully set forth

below.

71. Plaintiff, individually and on behalf of the Classes, asserts a common law claim for

unjust enrichment. This claim is brought solely in the alternative to Plaintiff’s breach of contract

claims and applies only if the parties’ contracts are deemed unconscionable or otherwise

unenforceable for any reason. In such circumstances, unjust enrichment will dictate that Defendant

disgorge all improperly assessed fees.

72. Plaintiff and members of the Classes conferred a benefit on Defendant at the

expense of Plaintiff and members of the Classes when they paid improper fees.

73. Defendant appreciated this benefit in the form of the substantial revenue that

Defendant generates from the imposition of such fees.

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74. Defendant has accepted and retained such fees under inequitable and unjust

circumstances.

75. Defendant should not be allowed to profit or enrich itself inequitably and unjustly

at the expense of Plaintiff and the members of the Classes and should be required to make

restitution to Plaintiff and members of the Classes.

CAUSE OF ACTION FOUR
Violations of New York General Business Law § 349, et seq.
(On Behalf of Plaintiff and the Classes)

76. Plaintiff incorporates by reference the preceding paragraphs.

77. Defendant’s improper fee practices as alleged herein violates New York Business

Law § 349 (“NYGBL § 349).

78. NYGBL § 349 prohibits deceptive acts or practices in the conduct of any business,

trade, or commerce, or in the furnishing of any service in the state of New York.

79. Defendant is headquartered in New York and has multiple banking locations in New

York. Accordingly, Defendant conducts business, trade, or commerce in New York State.

80. In the conduct of its business, trade, and commerce, and in furnishing services in

New York State, Defendant’s actions were directed at consumers.

81. In the conduct of its business, trade, and commerce, and in furnishing service in

New York State, Defendant engaged in deceptive, unfair, and unlawful trade, acts or practices, in

violation of NYGBL § 349(a), including but not limited to the following:

a. Defendant misrepresented material facts pertaining to the sale and/or furnishing of

banking services to Plaintiff and the Classes that it would not charge fees on

phantom transactions and that it would not charge fees when transactions did not

overdraw checking accounts;

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b. Defendant omitted, suppressed, and concealed the material fact that it would charge

more than one fee on an item;

82. Defendant systematically engaged in these deceptive, misleading, and unlawful

acts and practices, to the detriment of Plaintiff and members of the class.

83. Defendant willfully engaged in such acts and practices and knew that it violated

NYGBL § 349 or showed reckless disregard for whether it violated NYGBL § 349.

84. As a direct and proximate result of Defendant’s deceptive banking practices,

Plaintiff and members of the Classes suffered injury and/or damages, including the payment of

deceptive fees, as described herein, and the loss of the benefit of their respective bargains with

Defendant.

85. The unfair and deceptive practices by Defendant, as described herein, were

immoral, unethical, oppressive, and unscrupulous. These acts cause substantial injury to

consumers that these consumers could not reasonably avoid; this substantial injury outweighed

any benefits to consumers or competition.

86. Further, Defendant’s conduct was substantially injurious to Plaintiff and members

of the putative Classes in that they were forced to pay fees they were told they would not incur.

87. Defendant’s actions in engaging in the above-described unfair practices and

deceptive acts were negligent, knowing and willful, and/or wanton and reckless with respect to the

rights of the members of the Plaintiff and putative Classes.

88. Had Plaintiff and members of the putative Classes known they could be charged

the above-described deceptive fees, they would have attempted to avoid incurring such fees.

89. As a result of Defendant’s violations of NYGBL § 349, Plaintiff and the putative

Classes have suffered and will continue to suffer actual damages.

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90. Accordingly, Plaintiff and the members of the putative Classes are entitled to relief

under NYGBL § 349(h), including, but not limited to, actual damages, treble damages, statutory

damages, injunctive relief, and/or attorneys’ fees and costs.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff and members of the Classes demand a jury trial on all claims so

triable and judgment as follows:

a. Certification for this matter to proceed as a class action;

b. Designation of Plaintiff as the Class Representative and designation of the

undersigned as Class Counsel;

c. Restitution of all improper fees paid to Defendant by Plaintiff and the Classes

because of the wrongs alleged herein in an amount to be determined at trial;

d. Declaring Defendant’s fee policies and practices alleged in this Complaint to be

wrongful to the extent they are inconsistent with the contract;

e. Enjoining Defendant from engaging in the practices outlined herein so long as they

remain inconsistent with the contract;

f. Actual damages in amount according to proof;

g. Pre- and post-judgment interest at the maximum rate permitted by applicable law;

h. Costs and disbursements assessed by Plaintiff in connection with this action,

including reasonable attorneys’ fees pursuant to applicable law; and

i. Such other relief as the Court deems just and proper.

JURY DEMAND
Plaintiff, by counsel, demands trial by jury.

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Respectfully submitted,
.
/s/ _James J. Bilsborrow______
WEITZ & LUXENBERG, PC
700 Broadway
New York, NY 10003
Telephone: (212) 558-5500
jbilsborrow@weitzlux.com

JOHNSON FIRM
Christopher D. Jennings*
Tyler B. Ewigleben*
610 President Clinton Avenue, Suite 300
Little Rock, Arkansas 72201
Telephone: (501) 372-1300
chris@yourattorney.com
tyler@yourattorney.com

* Pro Hac Vice applications to be submitted

Counsel for Plaintiff and the Proposed
Classes

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TERMS AND CONDITIONS
OFYOURACCOUNT

AGREEMENT - Thisdocument, along with any
other documents we give you pertaining to
your account(s), is a contract that establishes
rules which control your account(s) with us.
Please read this carefully and retain it for future
reference. If you sign the signature card or open
or continue to use the account, you agree to
these rules. You will receive a separate schedule
of rates, qualifying balances, and fees if they are
not included in this document. If you have any
questions, please call us.
This agreement is subject to applicable federal
laws, the laws of the state of New York and other
applicable rules such as the operating letters
of the Federal Reserve Banks and payment
processing system rules (except to the extent
that this agreement can and does vary such
rules or laws). The body of state and federal law
that governs our relationship with you, however,
is too large and complex to be reproduced here.
The purpose of this document is to:
(1) summarize some laws that apply to
common transactions;
(2) establish rules to cover transactions or
events which the law does not regulate;
(3) establish rules for certain transactions
or events which the law regulates but
permits variation by agreement; and
(4) give you disclosures of some of our
policies to which you may be entitled or
in which you may be interested.
If any provision of this document is found to
be unenforceable according to its terms, all
remaining provisions will continue in full force
and effect. We may permit some variations
from our standard agreement, but we must
agree to any variation in writing either on the
signature,card for your account or in some other
document.
"we"
As used in this
document the words
"us"
"our", and mean the financial institution

Case Info

Judge

Richard Healy Track Judge’s New Case

Case No.

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Document Filed Date

September 22, 2023

Case Filing Date

April 27, 2023

County

Parties

BILSBORROW, JAMES JACKSON Attorney for the Plaintiff
KLEIN, GARY R Attorney
LYONS BANCORP INC Defendant
LYONS NATIONAL BANK Defendant
Michael Celso Plaintiff
Nicoletti & Harris Inc. Non Party
SMITH, LISA L. Attorney for the Defendant
WILLIAMS, SAMUEL M Attorney for the Defendant
CAROLYN NUSSBAUM Attorneys for Defendants
CHRISTOPHER JANNES Attorneys for Plaintiffs
JEFFREY KAPELMAN Attorneys for Plaintiffs

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Exhibit,Appendix: Michael Celso v. Lyons Bancorp Inc, Lyons National Bank

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Case Info

Parties