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  • American Express National Bank vs. Haroules, Mark Consumer Revolving Credit - M.R.C.P Rule 8.1 document preview
  • American Express National Bank vs. Haroules, Mark Consumer Revolving Credit - M.R.C.P Rule 8.1 document preview
  • American Express National Bank vs. Haroules, Mark Consumer Revolving Credit - M.R.C.P Rule 8.1 document preview
  • American Express National Bank vs. Haroules, Mark Consumer Revolving Credit - M.R.C.P Rule 8.1 document preview
						
                                

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Date Filed 3/21/2024 10:46 AM Superior Court - Middlesex Docket Number RECEIVED 3/21/2024 COMMONWEALTH OF MASSACHUSETTS MIDDLESEX SUPERIOR COURT L2 MIDDLESEX, ss CIVIL ACTION NO. 2481 CV00763 AMERICAN EXPRESS NATIONAL BANK Plaintiff, Vv MARK HAROULES Defendant. COMPLAINT American Express National Bank (“Plaintiff”) is a national bank organized under the laws of the United States, (“American Express” hereinafter), with its headquarters located at 115 W. Towne Ridge Parkway, Sandy, UT 84070. On April 1, 2018 American Express Centurion Bank changed its name to American Express National Bank. Defendant, Mark Haroules, is an individual residing at 118 Concord Rd, Westford, MA 01886-4003. Defendant entered into a Credit Card Agreement (“Agreement”) with American Express account ending #XXXXXXXXXXX1000. The last payment of $30,235.95 was received on June 18, 2023. Defendant used the credit card to make purchases and/or cash advances. Defendant defaulted on the agreement by failing to make payments as they came due. Defendant, after the application of all charges and credits to Defendant’s account, Defendant owes Plaintiff $53,599.93. RS Date Filed 3/21/2024 10:46 AM Superior Court - Middlesex Docket Number WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $53,599,93. Respectfully Submitted, American Express National Bank By its Attorney, Law Office of Randall L. Pratt Date: 4 ny / 4 de Op Randall L. Pratt, Esq. (BBO: Law Offices of Randall L, Pratt 53) One Cate Street Portsmouth, NH 03801 (603) 430-2888 rpratt@prattlawpc.com