On July 15, 2021 a
Complaint,Petition
was filed
involving a dispute between
American Express National Bank,
and
Black Gold Industries Llc,
Roberts, Van,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
7/15/2021 3:23 PM
FELICIA PITRE
1 ClT/ESERVE DISTRICT CLERK
DALLAS 00., TEXAS
Alicia Mata DEPUTY
DC-21 -09224
NO
AMERICAN EXPRESS NATIONAL § IN THE DISTRICT COURT
BANK, . .
§ 193rd
Plalntlff § JUDICIAL DISTRICT
V. §
§ DALLAS COUNTY, TEXAS
VAN ROBERTS and BLACK GOLD §
INDUSTRIES LLC, §
Defendant(s)
PLAINTIFF’S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
AMERICAN EXPRESS NATIONAL BANK, (“Plaintiff ’), complains of VAN ROBERTS and
BLACK GOLD INDUSTRIES LLC, (“Defendant(s)”), and for its cause of action would
respectfully show the Court as follows:
l. This cause of action is governed by the rules for Expedited Actions under the Texas
Rules of Civil Procedure Rule 169 because the Plaintiff is seeking only monetary relief of
two-hundred and fifiy thousand dollars or less excluding interest, statutory or punitive
damages and penalities, and attorney's fees and costs. Discovery is intended to be
conducted under Level l of Rule 190.2 of the Texas Rules of Civil Procedure. Damages
sought are within the jurisdictional limits of the court.
2. Plaintiff is a National Bank located in Utah. Plaintiff may be contacted through the
undersigned attorney.
AMERICAN EXPRESS NATIONAL BANK V. VAN ROBERTS and BLACK GOLD INDUSTRIES LLC
Plaintiff’ s Original Petition
3. Defendant VAN ROBERTS is a resident of DALLAS County, Texas, and may be served
with process at 1109 ASHINGTON PL, DESOTO, TX 75115. Venue is proper in this
Court because Defendant(s) resides/reside in this county at the time of the filing of this
suit.
4. Defendant BLACK GOLD INDUSTRIES LLC is a business entity and may be served
with process through its REGISTERED AGENT: VAN E ROBERTS at 2847 BARCO,
GMND PRAIRIE, TX 75054.
BREACH OF WRITTEN CONTRACT
5. Defendant(s) obtained a credit account from Plaintiff. The credit account is identified as
ending in account number 007.
6. Plaintiff and Defendant(s) entered into a credit account agreement (“the Agreement”).
Under the terms of the Agreement, Plaintiff rendered credit services to Defendant(s).
Defendant(s) accepted the credit services and under the Agreement became bound to pay
Plaintiff the amounts of such credit services, plus additional amounts due under the
Agreement.
7. Defendant(s) has/have failed to repay all of the credit services rendered under the
Agreement. The current balance due, owing and unpaid under the Agreement, after
allowing all just and lawful payments, credits and offsets, is $5,477.06. The terms of the
Agreement control the accrual of additional charges, interest, and other amounts.
Plaintiff has made demand upon Defendant(s) for payment of the balance due under the
Agreement, but Defendant(s) has/have failed to pay the balance.
8. All conditions precedent to Plaintiff s right to bring suit on its claims have been
performed or have occurred.
AMERICAN EXPRESS NATIONAL BANK V. VAN ROBERTS and BLACK GOLD INDUSTRIES LLC
Plaintiff’ s Original Petition
WHEREFORE, premises considered, the Plaintiff, AMERICAN EXPRESS NATIONAL
BANK, requests that Defendant(s), VAN ROBERTS and BLACK GOLD INDUSTRIES LLC,
be cited to appear and answer and that, upon final hearing, Plaintiff have judgment against
Defendant(s) for the following:
1. $5,477.06 as the balance due, owing, and unpaid under the Agreements;
2. All costs of this proceeding;
Respectfully submitted,
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
Attorneys for Plaintiff
PO BOX 168568,
IRVING, TX 75016
TEL: (833)510-2100
FAX: (972)591—0468
EMAIL: ZATDLIT@ZWICKERPC.COM
BY: flflagwb
[ 1DAVID L. WIstON
St te Bar Number 21787100
OLAWALE ADEOGUN
State Bar Number 24109562
[ ] ANTONY J. CHERIAN
State Bar Number 24087291
AMERICAN EXPRESS NATIONAL BANK V. VAN ROBERTS and BLACK GOLD INDUSTRIES LLC
Plaintiff’ s Original Petition
Document Filed Date
July 15, 2021
Case Filing Date
July 15, 2021
Category
CNTR CNSMR COM DEBT
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FILED 7/15/2021 3:23 PM FELICIA PITRE 1 ClT/ESERVE DISTRICT CLERK DALLAS 00., TEXAS Alicia Mata DEPUTY DC-21 -09224 NO AMERICAN EXPRESS NATIONAL § IN THE DISTRICT COURT BANK, . . § 193rd Plalntlff § JUDICIAL DISTRICT V. § § DALLAS COUNTY, TEXAS VAN ROBERTS and BLACK GOLD § INDUSTRIES LLC, § Defendant(s) PLAINTIFF’S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: AMERICAN EXPRESS NATIONAL BANK, (“Plaintiff ’), complains of VAN ROBERTS and BLACK GOLD INDUSTRIES LLC, (“Defendant(s)”), and for its cause of action would respectfully show the Court as follows: l. This cause of action is governed by the rules for Expedited Actions under the Texas Rules of Civil Procedure Rule 169 because the Plaintiff is seeking only monetary relief of two-hundred and fifiy thousand dollars or less excluding interest, statutory or punitive damages and penalities, and attorney's fees and costs. Discovery is intended to be conducted under Level l of Rule 190.2 of the Texas Rules of Civil Procedure. Damages sought are within the jurisdictional limits of the court. 2. Plaintiff is a National Bank located in Utah. Plaintiff may be contacted through the undersigned attorney. AMERICAN EXPRESS NATIONAL BANK V. VAN ROBERTS and BLACK GOLD INDUSTRIES LLC Plaintiff’ s Original Petition 3. Defendant VAN ROBERTS is a resident of DALLAS County, Texas, and may be served with process at 1109 ASHINGTON PL, DESOTO, TX 75115. Venue is proper in this Court because Defendant(s) resides/reside in this county at the time of the filing of this suit. 4. Defendant BLACK GOLD INDUSTRIES LLC is a business entity and may be served with process through its REGISTERED AGENT: VAN E ROBERTS at 2847 BARCO, GMND PRAIRIE, TX 75054. BREACH OF WRITTEN CONTRACT 5. Defendant(s) obtained a credit account from Plaintiff. The credit account is identified as ending in account number 007. 6. Plaintiff and Defendant(s) entered into a credit account agreement (“the Agreement”). Under the terms of the Agreement, Plaintiff rendered credit services to Defendant(s). Defendant(s) accepted the credit services and under the Agreement became bound to pay Plaintiff the amounts of such credit services, plus additional amounts due under the Agreement. 7. Defendant(s) has/have failed to repay all of the credit services rendered under the Agreement. The current balance due, owing and unpaid under the Agreement, after allowing all just and lawful payments, credits and offsets, is $5,477.06. The terms of the Agreement control the accrual of additional charges, interest, and other amounts. Plaintiff has made demand upon Defendant(s) for payment of the balance due under the Agreement, but Defendant(s) has/have failed to pay the balance. 8. All conditions precedent to Plaintiff s right to bring suit on its claims have been performed or have occurred. AMERICAN EXPRESS NATIONAL BANK V. VAN ROBERTS and BLACK GOLD INDUSTRIES LLC Plaintiff’ s Original Petition WHEREFORE, premises considered, the Plaintiff, AMERICAN EXPRESS NATIONAL BANK, requests that Defendant(s), VAN ROBERTS and BLACK GOLD INDUSTRIES LLC, be cited to appear and answer and that, upon final hearing, Plaintiff have judgment against Defendant(s) for the following: 1. $5,477.06 as the balance due, owing, and unpaid under the Agreements; 2. All costs of this proceeding; Respectfully submitted, ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection Attorneys for Plaintiff PO BOX 168568, IRVING, TX 75016 TEL: (833)510-2100 FAX: (972)591—0468 EMAIL: ZATDLIT@ZWICKERPC.COM BY: flflagwb [ 1DAVID L. WIstON St te Bar Number 21787100 OLAWALE ADEOGUN State Bar Number 24109562 [ ] ANTONY J. CHERIAN State Bar Number 24087291 AMERICAN EXPRESS NATIONAL BANK V. VAN ROBERTS and BLACK GOLD INDUSTRIES LLC Plaintiff’ s Original Petition