Preview
FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024
CONSUMER CREDIT TRANSACTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
AMERICAN EXPRESS NATIONAL BANK, Plaintiff designates Ulster County
as the place of trial
Plaintiff,
Index No.
-against-
Date Purchased:
MATTHEW GREENFIELD
SUMMONS
The basis of the venue
designated is:
Defendants. Defendant's place of residence.
To: MATTHEW GREENFIELD
106 Lippincott Road # 2
Wallkill, NY 12589
Plaintiffs'
YOU ARE HEREBY SUMMONED and required to serve upon attorney, at
the address stated below, an answer to the attached complaint.
If this summons was personally delivered to you in the State of New York, the answer
must be served within twenty days after such service of summons, excluding the date of service.
If the summons was not personally delivered to you within the State of New York, the answer
must be served within thirty days after service of the summons is complete as provided by law.
If you do not serve an answer to the attached complaint or otherwise appear within the
applicable time limitation stated above, a judgment may be entered against you by default for the
relief demanded in the complaint without further notice to you.
The action will be heard in the Supreme Court of the State of New York, in and for the
County of Ulster, 285 Wall St., Kingston, NY 12401.
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This action is brought in the County of Ulster because it is the place of defendant's residence,
with an address at: 106 Lippincott Road # 2, Wallkill, New York 12589.
Dated: February 28, 2024
nthody J gliaccio, Jr., Esq.
V Benjamin Marashlian, Esq.
Alexander Fink, Esq.
Staff Attorneys for the Plaintiff,
BANK1
AMERICAN EXPRESS NATIONAL
Please send all correspondence to:
AMERICAN EXPRESS LEGAL
P.O. Box 119
Suffem, NY 10901
(877) 305 -0433
AMERICAN EXPRESS LEGAL
American Express Tower
World Financial Center
22nd
200 Vesey Street FlOOr
New York, NY 10285
877-305-0433
File No 6325020
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
AMERICAN EXPRESS NATIONAL BANK,
Index No.:
Plaintiff,
-against- COMPLAINT
MATTHEW GREENFIELD,
Defendant.
BANK¹
Plaintiff, AMERICAN EXPRESS NATIONAL ("American Express"), by and
through its attorneys, as and for its complaint herein against defendant Matthew Greenfield
("Greenfield"), hereby alleges as follows:
The Parties
BANKI
1. AMERICAN EXPRESS NATIONAL ("American Express"), a
national bank under the laws of the United States of America with its office located at 115 W.
Town Ridge Parkway, Sandy, Utah 84070 (hereinafter singularly or collectively referenced as
"American Express"), and is the original creditor.
2. Upon information and belief, at all relevant times, Greenfield was and is an
individual who resides in the State of New York, County of Ulster, at 106 Lippincott Road # 2,
Wallkill, New York 12589.
¹ On April
1, 2018 American Express Centurion Bank changed its name to American Express National Bank and
American Express Bank FSB, merged with American Express National Bank with American Express National Bank
as the surviving after the merger. See, https://www.occ.treas.gov/topics/licensing/interpretations-and-
entity
actions/2018/interpretations-and-actions-jan-2018.html. See also, 12 U.S.C. § 35; 12 CFR 5.24 and 12 U.S.C. §
1828 et seq.
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The Facts
The Blue Cash Preferred from American Express Card Account
3. At all relevant times, Greenfield was the holder of a Blue Cash Preferred from
American Express Card (the "Blue Cash Preferred from American Express Card") that enabled
him/her to charge items to the Blue Cash Preferred from American Express Card account
Express"
(account no. xxxx-xxxxxx-x5003) (the "Blue Cash Preferred from American Account).
4. By accepting and using the Blue Cash Preferred from American Express,
Greenfield agreed to all of the terms and conditions set forth in the "Business Charge Card
Agreement"
(the "Agreement"), which was provided to Greenfield with the Blue Cash Preferred
from American Express Card (A copy of the Business Charge Card Agreement is attached hereto
as Exhibit "A").
5. The terms and conditions of the Agreement between the Card Member and
American Express include the following:
a. Greenfield agreed to be responsible for paying all amounts charged to the
Blue Cash Preferred from American Express Card Account.
Due"
b. Greenfield agreed to pay the "Minimum Amount by the due date
indicated on the monthly billing statements mailed by or on behalf of
American Express.
c. Greenfield agreed that American Express may impose late fees, in amounts
set forth in the Agreement, on all unpaid amounts.
"default"
d. Greenfield further agreed that, upon (as that term is used in the
Agreement) he/she would pay all reasonable costs incurred by American
Express in protecting itself from any harm it may suffer as a result of any
such default.
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The Default
6. Greenfield used the Blue Cash Preferred from American Express to charge
various items to the Blue Cash Preferred from American Express Card Account for which he/she
never made payment.
7. American Express sent monthly statements to Greenfield for the Account,
showing the Minimum Amount Due on the Blue Cash Preferred from American Express Card
Account.
8. The final statement of account was provided to Defendant(s) on or about February
2, 2024.
9. Greenfield violated the Agreement by refusing to remit the Minimum Amount
Due indicated by the monthly statements.
10. The amount of the last posted payment, if any, made to the Account was
$1,150.00, made on July 28, 2023.
11. The account balance printed on the most recent monthly statement recording a
payment was $13,636.49.
12. Greenfield's failure to pay the Minimum Amount Due constituted a default under
the Agreement and lead to the account becoming delinquent. As a result, American Express
suspended Greenfield's charge privileges on the Blue Cash Preferred from American Express
Card Account and the outstanding balance became due in its entirety.
13. Thus, due to Greenfield's failure to remit timely payment to American Express,
there is due and owing to American Express the balance of $15,004.87.
14. The Account is not charged-off.
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AS AND FOR A FIRST CAUSE OF ACTION
(Breach of Contract: )
15. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs
1 through 14 of this complaint as though fully set forth at length herein.
16. In violation of the Agreement requiring payment of the Minimum Amount Due on
the Blue Cash Preferred from American Express Card Account, Greenfield has failed and refused
to make the payments to American Express as set forth in the Blue Cash Preferred from
American Express Card monthly statements. As a result, American Express suspended
Greenfield's charge privileges on the Blue Cash Preferred from American Express Card
Account.
17. Greenfield agreed to pay for all items charged to the Blue Cash Preferred from
American Express Card Account. In addition, Greenfield agreed to pay American Express late
fees and court costs in the event that American Express referred the Blue Cash Preferred from
American Express Card Account to its attorneys for collection.
18. As set forth above, Greenfield is currently indebted to American Express for
unpaid charges in the amount of $15,004.87.
19. Despite due demand, Greenfield has failed and refused to pay American Express
any portion of the amount due and owing.
20. As a result of Greenfield's failure to pay the amount that he/she owes, American
Express referred its claim against Greenfield to its attorneys for collection.
21. By reason of the foregoing, American Express is entitled to judgment against
Greenfield for breach of contract in the sum of $15,004.87, plus court costs.
AS AND FOR A SECOND CAUSE OF ACTION
(Account Stated: )
22. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs
1 through 21 of this complaint as though fully set forth at length herein.
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23. American Express duly issued and sent to Greenfield, the Blue Cash Preferred
from American Express Card monthly statements which set forth in detail all items charged to
the Blue Cash Preferred from American Express Card Account and the total amount due and
owing by Greenfield to American Express on the Blue Cash Preferred from American Express
Card Account.
24. Greenfield received the Blue Cash Preferred from American Express Card
monthly statements without protest and neither objected to them nor indicated that they were
erroneous in any respect. Greenfield thereby acknowledged that the debt owed to American
Express, as set forth in the Blue Cash Preferred from American Express Card monthly
statements, is true and correct.
25. By reason of the foregoing, American Express is entitled to judgment against
Greenfield for an account stated in the amount of $15,004.87 plus court costs.
AS AND FOR A THIRD CAUSE OF ACTION
(Unjust Enrichment: )
26. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs
1 through 25 of this complaint as though fully set forth at length herein.
27. Greenfield benefited from all of the charges made to the Blue Cash Preferred
from American Express Card Account, has acknowledged receipt of those benefits, and has
failed to pay for same.
28. Given Greenfield's failure to make payment for the outstanding balance owed
with respect to the Blue Cash Preferred from American Express Card Account, and the fact that
Greenfield was the beneficiary of all items charged to the Blue Cash Preferred from American
Express Card Account, Greenfield would be unjustly enriched to American Express's detriment
unless judgment is entered against them for the full balance due and owing on the Blue Cash
Preferred from American Express Card Account.
29. As set forth above, Greenfield has been unjustly enriched to American Express's
detriment.
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30. By reason of the foregoing, American Express is entitled to judgment against
Greenfield for unjust enrichment in an amount to be determined at trial, plus court costs.
WHEREFORE, plaintiff AMERICAN EXPRESS NATIONAL BANK requests
judgment against Defendant, MATTHEW GREENFIELD as follows:
(i) As for the first cause of action, plaintiff AMERICAN EXPRESS NATIONAL
BANK requests judgment against MATTHEW GREENFIELD in the sum of
$15,004.87 plus court costs;
(ii) As for the second cause of action of the complaint, plaintiff AMERICAN
EXPRESS NATIONAL BANK requests judgment against MATTHEW
GREENFIELD in an amount of $15,004.87 plus court costs;
(iii) As for the third cause of action, plaintiff AMERICAN EXPRESS NATIONAL
BANK requests judgment against MATTHEW GREENFIELD in an amount to be
determined at trial, plus court costs; and
(iv) For such other and further relief as this Court deems just and proper.
Dated: February 28, 2024
nt on J (Iigliaccio, Jr., Esq.
__VBenjamin Marashlian, Esq.
__Alexander Fink, Esq.
Staff Attorneys for the Plaintiff,
AMERICAN NATIONAL BANKI
EXPRESS
Please send all correspondence to:
AMERICAN EXPRESS LEGAL
P.O. Box 119
Suffern, NY 10901
(877) 305 -0433
AMERICAN EXPRESS LEGAL
American Express Tower
World Financial Center
22nd
200 Vesey Street FlOOr
New York, NY 10285
877-305-0433
File No 6325020
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Rule 130-1.1a
Pursuant to 22 NYCRR 130-1.1a, the undersigned attomey hereby certifies under the penalties of
perjury and as an officer of the court that to the best of my knowledge, information and belief,
formed after an inquiry reasonable under the circumstances, the presentation of this document or
the contentions therein are not frivolous.
AntlJ6ny/J. Migliaccio, Jr., Esq.
2Benjamin Marashlian, Esq.
__Alexander Fink, Esq.
File No 6325020
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
AMERICAN EXPRESS NATIONAL BANK,
Index No.
Plaintiff,
-against-
MATTHEW GREENFIELD
Defendant.
SUMMONS AND COMPLAINT
Plaintiff
AMERICAN EXPRESS LEGAL
AntBfonf J. igliaccio, Jr., Esq.
EBenjamin Marashlian, Esq.
Alexander Fink, Esq.
5t-aff Attorneys for the Plaintiff,
Bank¹
American Express National
Please send all correspondence to:
AMERICAN EXPRESS LEGAL
P.O. Box 119
Suffern, NY 10901
(877) 305 -0433
AMERICAN EXPRESS LEGAL
American Express Tower
World Financial Center
22nd
200 Vesey Street FlOOr
New York, NY 10285
877-305-0433
File No 6325020
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Preview
FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 CONSUMER CREDIT TRANSACTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER AMERICAN EXPRESS NATIONAL BANK, Plaintiff designates Ulster County as the place of trial Plaintiff, Index No. -against- Date Purchased: MATTHEW GREENFIELD SUMMONS The basis of the venue designated is: Defendants. Defendant's place of residence. To: MATTHEW GREENFIELD 106 Lippincott Road # 2 Wallkill, NY 12589 Plaintiffs' YOU ARE HEREBY SUMMONED and required to serve upon attorney, at the address stated below, an answer to the attached complaint. If this summons was personally delivered to you in the State of New York, the answer must be served within twenty days after such service of summons, excluding the date of service. If the summons was not personally delivered to you within the State of New York, the answer must be served within thirty days after service of the summons is complete as provided by law. If you do not serve an answer to the attached complaint or otherwise appear within the applicable time limitation stated above, a judgment may be entered against you by default for the relief demanded in the complaint without further notice to you. The action will be heard in the Supreme Court of the State of New York, in and for the County of Ulster, 285 Wall St., Kingston, NY 12401. File No 6325020 1 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 This action is brought in the County of Ulster because it is the place of defendant's residence, with an address at: 106 Lippincott Road # 2, Wallkill, New York 12589. Dated: February 28, 2024 nthody J gliaccio, Jr., Esq. V Benjamin Marashlian, Esq. Alexander Fink, Esq. Staff Attorneys for the Plaintiff, BANK1 AMERICAN EXPRESS NATIONAL Please send all correspondence to: AMERICAN EXPRESS LEGAL P.O. Box 119 Suffem, NY 10901 (877) 305 -0433 AMERICAN EXPRESS LEGAL American Express Tower World Financial Center 22nd 200 Vesey Street FlOOr New York, NY 10285 877-305-0433 File No 6325020 2 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER AMERICAN EXPRESS NATIONAL BANK, Index No.: Plaintiff, -against- COMPLAINT MATTHEW GREENFIELD, Defendant. BANK¹ Plaintiff, AMERICAN EXPRESS NATIONAL ("American Express"), by and through its attorneys, as and for its complaint herein against defendant Matthew Greenfield ("Greenfield"), hereby alleges as follows: The Parties BANKI 1. AMERICAN EXPRESS NATIONAL ("American Express"), a national bank under the laws of the United States of America with its office located at 115 W. Town Ridge Parkway, Sandy, Utah 84070 (hereinafter singularly or collectively referenced as "American Express"), and is the original creditor. 2. Upon information and belief, at all relevant times, Greenfield was and is an individual who resides in the State of New York, County of Ulster, at 106 Lippincott Road # 2, Wallkill, New York 12589. ¹ On April 1, 2018 American Express Centurion Bank changed its name to American Express National Bank and American Express Bank FSB, merged with American Express National Bank with American Express National Bank as the surviving after the merger. See, https://www.occ.treas.gov/topics/licensing/interpretations-and- entity actions/2018/interpretations-and-actions-jan-2018.html. See also, 12 U.S.C. § 35; 12 CFR 5.24 and 12 U.S.C. § 1828 et seq. File No 6325020 3 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 The Facts The Blue Cash Preferred from American Express Card Account 3. At all relevant times, Greenfield was the holder of a Blue Cash Preferred from American Express Card (the "Blue Cash Preferred from American Express Card") that enabled him/her to charge items to the Blue Cash Preferred from American Express Card account Express" (account no. xxxx-xxxxxx-x5003) (the "Blue Cash Preferred from American Account). 4. By accepting and using the Blue Cash Preferred from American Express, Greenfield agreed to all of the terms and conditions set forth in the "Business Charge Card Agreement" (the "Agreement"), which was provided to Greenfield with the Blue Cash Preferred from American Express Card (A copy of the Business Charge Card Agreement is attached hereto as Exhibit "A"). 5. The terms and conditions of the Agreement between the Card Member and American Express include the following: a. Greenfield agreed to be responsible for paying all amounts charged to the Blue Cash Preferred from American Express Card Account. Due" b. Greenfield agreed to pay the "Minimum Amount by the due date indicated on the monthly billing statements mailed by or on behalf of American Express. c. Greenfield agreed that American Express may impose late fees, in amounts set forth in the Agreement, on all unpaid amounts. "default" d. Greenfield further agreed that, upon (as that term is used in the Agreement) he/she would pay all reasonable costs incurred by American Express in protecting itself from any harm it may suffer as a result of any such default. File No 6325020 4 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 The Default 6. Greenfield used the Blue Cash Preferred from American Express to charge various items to the Blue Cash Preferred from American Express Card Account for which he/she never made payment. 7. American Express sent monthly statements to Greenfield for the Account, showing the Minimum Amount Due on the Blue Cash Preferred from American Express Card Account. 8. The final statement of account was provided to Defendant(s) on or about February 2, 2024. 9. Greenfield violated the Agreement by refusing to remit the Minimum Amount Due indicated by the monthly statements. 10. The amount of the last posted payment, if any, made to the Account was $1,150.00, made on July 28, 2023. 11. The account balance printed on the most recent monthly statement recording a payment was $13,636.49. 12. Greenfield's failure to pay the Minimum Amount Due constituted a default under the Agreement and lead to the account becoming delinquent. As a result, American Express suspended Greenfield's charge privileges on the Blue Cash Preferred from American Express Card Account and the outstanding balance became due in its entirety. 13. Thus, due to Greenfield's failure to remit timely payment to American Express, there is due and owing to American Express the balance of $15,004.87. 14. The Account is not charged-off. File No 6325020 5 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 AS AND FOR A FIRST CAUSE OF ACTION (Breach of Contract: ) 15. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1 through 14 of this complaint as though fully set forth at length herein. 16. In violation of the Agreement requiring payment of the Minimum Amount Due on the Blue Cash Preferred from American Express Card Account, Greenfield has failed and refused to make the payments to American Express as set forth in the Blue Cash Preferred from American Express Card monthly statements. As a result, American Express suspended Greenfield's charge privileges on the Blue Cash Preferred from American Express Card Account. 17. Greenfield agreed to pay for all items charged to the Blue Cash Preferred from American Express Card Account. In addition, Greenfield agreed to pay American Express late fees and court costs in the event that American Express referred the Blue Cash Preferred from American Express Card Account to its attorneys for collection. 18. As set forth above, Greenfield is currently indebted to American Express for unpaid charges in the amount of $15,004.87. 19. Despite due demand, Greenfield has failed and refused to pay American Express any portion of the amount due and owing. 20. As a result of Greenfield's failure to pay the amount that he/she owes, American Express referred its claim against Greenfield to its attorneys for collection. 21. By reason of the foregoing, American Express is entitled to judgment against Greenfield for breach of contract in the sum of $15,004.87, plus court costs. AS AND FOR A SECOND CAUSE OF ACTION (Account Stated: ) 22. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1 through 21 of this complaint as though fully set forth at length herein. File No 6325020 6 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 23. American Express duly issued and sent to Greenfield, the Blue Cash Preferred from American Express Card monthly statements which set forth in detail all items charged to the Blue Cash Preferred from American Express Card Account and the total amount due and owing by Greenfield to American Express on the Blue Cash Preferred from American Express Card Account. 24. Greenfield received the Blue Cash Preferred from American Express Card monthly statements without protest and neither objected to them nor indicated that they were erroneous in any respect. Greenfield thereby acknowledged that the debt owed to American Express, as set forth in the Blue Cash Preferred from American Express Card monthly statements, is true and correct. 25. By reason of the foregoing, American Express is entitled to judgment against Greenfield for an account stated in the amount of $15,004.87 plus court costs. AS AND FOR A THIRD CAUSE OF ACTION (Unjust Enrichment: ) 26. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1 through 25 of this complaint as though fully set forth at length herein. 27. Greenfield benefited from all of the charges made to the Blue Cash Preferred from American Express Card Account, has acknowledged receipt of those benefits, and has failed to pay for same. 28. Given Greenfield's failure to make payment for the outstanding balance owed with respect to the Blue Cash Preferred from American Express Card Account, and the fact that Greenfield was the beneficiary of all items charged to the Blue Cash Preferred from American Express Card Account, Greenfield would be unjustly enriched to American Express's detriment unless judgment is entered against them for the full balance due and owing on the Blue Cash Preferred from American Express Card Account. 29. As set forth above, Greenfield has been unjustly enriched to American Express's detriment. File No 6325020 7 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 30. By reason of the foregoing, American Express is entitled to judgment against Greenfield for unjust enrichment in an amount to be determined at trial, plus court costs. WHEREFORE, plaintiff AMERICAN EXPRESS NATIONAL BANK requests judgment against Defendant, MATTHEW GREENFIELD as follows: (i) As for the first cause of action, plaintiff AMERICAN EXPRESS NATIONAL BANK requests judgment against MATTHEW GREENFIELD in the sum of $15,004.87 plus court costs; (ii) As for the second cause of action of the complaint, plaintiff AMERICAN EXPRESS NATIONAL BANK requests judgment against MATTHEW GREENFIELD in an amount of $15,004.87 plus court costs; (iii) As for the third cause of action, plaintiff AMERICAN EXPRESS NATIONAL BANK requests judgment against MATTHEW GREENFIELD in an amount to be determined at trial, plus court costs; and (iv) For such other and further relief as this Court deems just and proper. Dated: February 28, 2024 nt on J (Iigliaccio, Jr., Esq. __VBenjamin Marashlian, Esq. __Alexander Fink, Esq. Staff Attorneys for the Plaintiff, AMERICAN NATIONAL BANKI EXPRESS Please send all correspondence to: AMERICAN EXPRESS LEGAL P.O. Box 119 Suffern, NY 10901 (877) 305 -0433 AMERICAN EXPRESS LEGAL American Express Tower World Financial Center 22nd 200 Vesey Street FlOOr New York, NY 10285 877-305-0433 File No 6325020 8 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 Rule 130-1.1a Pursuant to 22 NYCRR 130-1.1a, the undersigned attomey hereby certifies under the penalties of perjury and as an officer of the court that to the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of this document or the contentions therein are not frivolous. AntlJ6ny/J. Migliaccio, Jr., Esq. 2Benjamin Marashlian, Esq. __Alexander Fink, Esq. File No 6325020 9 of 10 FILED: ULSTER COUNTY CLERK 03/04/2024 01:35 PM INDEX NO. EF2024-593 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/04/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER AMERICAN EXPRESS NATIONAL BANK, Index No. Plaintiff, -against- MATTHEW GREENFIELD Defendant. SUMMONS AND COMPLAINT Plaintiff AMERICAN EXPRESS LEGAL AntBfonf J. igliaccio, Jr., Esq. EBenjamin Marashlian, Esq. Alexander Fink, Esq. 5t-aff Attorneys for the Plaintiff, Bank¹ American Express National Please send all correspondence to: AMERICAN EXPRESS LEGAL P.O. Box 119 Suffern, NY 10901 (877) 305 -0433 AMERICAN EXPRESS LEGAL American Express Tower World Financial Center 22nd 200 Vesey Street FlOOr New York, NY 10285 877-305-0433 File No 6325020 10 of 10