`
`
`
`(203)967-1190*TurisNo.421741
`
`LLC
`SANK&ASSOCIATES,
`
`MARK
`
`
`
`
`
`
`
`666GlenbrookRoad*Stamford,crrrrerreenenneenrerernietnieatennantennatatntiicinnietcnetnneacatsintttnrrmtintsttiatitttiettetineittitterrentpenneeeetiinmenesettttcttteettentneisnnetettttntanttesantcnninere=reneener,
`
`RETURN DATE:
`
`11/03/2020
`
`AMERICAN EXPRESS NATIONAL BANK _
`
`VS.
`
`KWAME CHISANGO
`CHISANGO LOGISTICS LLC
`
`‘
`
`:
`
`:
`
`:
`COMPLAINT
`
`COUNT ONE
`
`AS TO DEFENDANT KWAME CHISANGO:
`
`1) The Defendant, KWAME CHISANGO , was the holder of an
`
`SUPERIOR COURT
`
`J.D. OF HARTFORD
`
`AT HARTFORD
`
`SEPTEMBER 22, 2020
`
`AMERICAN EXPRESScredit card (the “Account”) that enabled the Defendantto charge items to the
`
`.
`Account.
`2) The Defendant, KWAME CHISANGO applied for an AMERICAN EXPRESScreditcard.
`
`3) As the applicant for an AMERICAN EXPRESS credit card, the Defendant, KWAME CHISANGO :
`
`provided personal financial disclosures required by the Plaintiff's application procedure.
`
`4) The Account numberissued was xxxxxxxxxx11004.
`
`5) The Account was opened by the Defendant on 04/03/2018.
`
`6) The Account was available to be used by the Defendant from 04/03/2018.
`
`7) The last payment on the Account was made on 03/27/2020.
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`8) Use of the Account binds the Defendant to the terms and conditions set forth in the AMERICAN
`
`EXPRESS Cardmember Agreement.
`
`9) By use of said Account, Defendant became indebted in the sum of $29,176.14.
`
`10) After repeated demandsfor payment, Defendant remains indebted in the sum of $29,176.14
`
`which amount remains outstanding.
`
`
`
`
`
`ATTORNEYSATLAW DG690G©
`
`Tels
`
`CT
`
`
`
`
`
`MARKSANK&ASSOCIATES,LLCATTORNEYSATLAW
`
`-TEon
`
`421741
`*lurisNo.
`
`Tel:(2035967
`CT§6906¢
`
`
`
`6606GlenbrookRoad*Stamford,
`
`COUNT TWO
`
`AS TO DEFENDANT KWAME CHISANGO :
`
`1) The Defendant, KWAME CHISANGO , was the holder of an AMERICAN EXPRESScredit card {the
`
`“Account”) that enabled the Defendant to charge items to the Account.
`
`2) The Defendant, KWAME CHISANGO applied for an AMERICAN EXPRESScredit card.
`
`3) As the applicant for an AMERICAN EXPRESScredit card, the Defendant, KWAME CHISANGO,
`
`provided personal financial disclosures required by the Plaintiff's application procedure.
`
`4) The Account number issued was xxxxxxxxxx11004.
`
`5) The Account was opened by the Defendant on 04/03/2018.
`
`6) The Account was available to be used by the Defendant from 04/03/2018.
`
`7) The last payment on the Account was made on 03/27/2020.
`
`8) Use of the Account binds the Defendant to the terms and conditions set forth in the AMERICAN
`
`EXPRESS Cardmember Agreement.
`
`9) By use of said Account, Defendant became indebted in the sum of $29,176.14 which amount
`
`remains outstanding.
`
`10) The Plaintiff regularly generated account statements reflecting an unpaid balance and mailed
`
`them to the Defendant; said statements were neither disputed nor returned.
`
`
`
`
`
`
`
`
`
`COUNT THREE
`
`AS TO DEFENDANT CHISANGO LOGISTICS LEC :
`
`
`
`
`
`1) The Defendant, CHISANGO LOGISTICS LLC , was the holder of an AMERICAN EXPRESS credit card
`
`{the “Account”) that enabled the Defendant to charge items to the Account.
`
`2) The Account numberissued was xxxxxxxxxx11004.
`
`3) The Account was available to be used by the Defendant from 04/03/2018.
`
`
`
`~-E190)*fusisNo.4271741
`
`4) The last payment on the Account was made on 03/27/2020.
`
` 5) Use of the Account binds the Defendant to the terms and conditions set forth in the AMERICAN
`
`NEYSATLAW O690*606GlenbrankRuad*Stamford, 7) The Defendanthas failed and refused to make paymenton the outstanding balance by reason of
`
`r e
`
`y S
`
`S
`ony
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`EXPRESS Cardmember Agreement.
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`6) By use of said Account, Defendant became indebted in the sum of $29,176.14.
`
`ATTOR
`
`cr
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`which the entire indebtednessif immediately due and payable.
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`
`
`
`
`
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`MARKSANK&ASSOCIATES.LLC
`
`
`
`
`
`ATTORNEYSATLAW
`
`S.LLC
`
`EK&ASSOCIAT
`MARKS
`
`
`
`Tek(203)967-1190JurisNo.421741
`
`
`
`
`
`DO9UG
`amford,CT
`sRoad*Sy
`666Gleabroo
`
`COUNT FOUR
`
`AS TO DEFENDANT CHISANGO LOGISTICS LLC :
`
`1} The Defendant, CHISANGO LOGISTICS LLC, was the holder of an AMERICAN EXPRESS credit card
`
`(the “Account”) that enabled the Defendantto charge items to the Account.
`2) The Accountnumberissued WAS XXXXXXXXXX11004.
`3) The Account was available to be used by the Defendant from 04/03/2018.
`
`4) The last payment on the Account was made on 03/27/2020.
`
`5) Use of the Account binds the Defendant to the terms and conditions set forth in the AMERICAN
`
`EXPRESS Cardmember Agreement.
`
`6) By use of said Account, Defendant becameindebted in the sum of $29,176.14 which amount
`
`remains outstanding.
`
`7) The Plaintiff regularly generated account statements reflecting an unpaid balance and mailed
`
`them to the Defendant; said statements were neither disputed nor returned.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`| WHEREFORE,the Plaintiff claims:
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`|
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`1. Monetary damages.
`
`2. Costs of action.
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`3. An order on the Defendant for reasonable weekly payments out of sums earned or to be
`earned.
`
`4, The amount in demand is greater than FIFTEEN THOUSAND AND 00/100 ($15,000.00)
`DOLLARS.
`.
`
`
`
`
`
`
`
`
`
`
`LLCA.
`
`SANK&ASSOCIATES
`MARK
`
`ATTORNEYSATLAW
`
`21741A4
`
`Tel:(2U3)967-
`
`
`C690&
`
`G66GlenbrookRoad*Seamford,CT
`
`1i90©JurisNo.erinmeemreeneetetctetnseetn!tsiiennaueesttetatteettetalettltnentiAtttn—me——tentepttneattetttanteaterekstanyaetstesttsiytssnttntsissnsstiinnnrnnnmmrnentnstevenenntyenanamaatnteneettetemerntmceeittekswae
`
`5. The remedy sought is based upon an express or implied promise to pay a definite sum.
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`
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`
`
`
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`|, Mark A. Sank, the subscribing authority, hereby certify that | have personal knowledge as
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`to the financial responsibility of the Plaintiff and deem it sufficient to pay the costs in this
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`action.
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`Of this Writ, with your doings thereon, make due service and return.
`
` Dated at Stamford, Connecticut on September 22, 2020
`
`
`
`Mark A Aank
`
`Please enter my appearance:
`
`’ Mark Sank & Associates, LLC
`666 Glenbrook Road
`Stamford, CT 06906
`{800} 785-9702
`Juris No. 421741
`
`For the Plaintiff
`
`42174)
`JurisNo.
`
`(ROU)785-0702©\
`
`GG906€Tel:
`c660GlenbrookRoad©Stamford,
`
`~C
`
`LLC
`
`VIARKSANK&ASSOCIATEShk
`
`ATTORNEYSATLAW
`
`
`
`
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