Party Discovery: AMERICAN EXPRESS NATIONAL BANK vs CHILUKAMUKKU

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                                AARON BALDARO, Esq. — State Bar ¹261156
                      SCOTT D.      DYLE, Esq. — State Bar ¹300917
                  2   AMERICAN EXPRESS LEGAL
                      199 South Los Robles Ave.,         Suite 540
                  3   Pasadena, CA 91101
                      Telephone:       (626) 660-0001
                  4   Fax:             (626) 298-6716
                      aaron.n.baldaro@aexp.corn
                      scott.d.dyle@aexp.corn
                  6   Attorneys    for Plaintiff American Express National Bank




                  9                            SUPERIOR COURT OF THE STATE OF CALIFORNIA
                 10          COUNTY OF ALAMEDA — HAYWARD HALL OF JUSTICE — UNLIMITED CIVIL


                                                                                  )
                 12    AMERICAN EXPRESS NATIONAL BANK,                             )  Case No.:    21CV000230
                                                                                   )
                 13                                    Plaintiff.                  )  PLAINTIFF'S SUMMARY OF THE
                                                                                   )  CASE
                 14             vs.                                                )
                                                                                   )
                 15    SANDEEP       CHILUKAMUKKU,                                 )
                                                                                   )
                 16                                    Defendant.                  )
                                                                                   )
                 17                                                                )
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                 18                                                                )
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                               Plaintiff American Express National Bank (" Plaintiff'r "American Express'*)                    submits the
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                       following summary of its case:
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                            1.      Defendant Sandeep Chilukamukku (" Defendant" ) applied for and received credit from
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                       Plaintiff to be used for the purchase of goods, wares and services.
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                           2.       As a condition of receiving the credit, Defendant agreed to make regular monthly
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                       payments to Plaintiff.     Defendant has defaulted on making those monthly payments, and Plaintiff
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                       has brought this action to recover the outstanding balance owed on Defendant's American Express
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                       credit card accounts.
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                                                                                 -I-
                                                             PLAINTIFF'S SUMMARY OF THE CASE
                  1        3.      The records of Plaintiff reflect that Defendant obtained American Express credit card

                  2   accounts    XXXX-XXXXXX-X3004, XXXX-XXXXXX-X1004 and XXXX-XXXXXX-X1004.

                  3   Defendant used the accounts and incurred a balance owed to Plaintiff.

                  4        4.      Plaintiff prepared and sent monthly billing statements to Defendant.               Defendant did not
                  5   object to the balance shown in the billing statements.

                  6        5.      Defendant has failed to make the required monthly payments on the accounts.                    At the
                  7   time of filing suit, the current outstanding balance that Defendant owed to Plaintiff was

                  8    $ 36,417.32.  This figure is calculated as $ 29,738.41       due on account XXXX-XXXXXX-X3004,

                  9    $ 5,222.28   due on account XXXX-XXXXXX-X1004 and $ 1,456.63                      due on account XXXX-

                 10    XXXXXX-X 1004.

                 11        6.      Defendant has not made any payments to Plaintiff since the filing of this suit and the

                 12    amount of $ 36,417.32 is still due and owing.

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                       Dated:   Sanuarv 26, 2022                                     By:
                                                                                        AMERlCA~XPRESS LEGAL
                 15                                                                     Aaron N. Baldaro, Esq.
                                                                                        Attorneys for Plaintiff
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                                                             PLAINTIFF'S SUMMARY OF THE CASE