Complaint Limited 10K and 25KCal. Super. - 6th Dist.September 23, 2020A)TORNEY OR PARTY WITHOUT ATTORNEY (Name, Stets Bar number and address) Spencer Penuela, Esu. (SBN: 324544) MICHAEL & ASSOCIATES, PC 555 St. Charles Drive, Suite 204, Thousand Oaks, CA 91360 TELEPHONE NO (805) 379-8505 FAx NO (Optronsl) (805) 379-8525 EsdAIL ADDRESS lDP(rona)) ATTORNEY FoR (Name) American Express National Bank fikls American Express Centurion Bank SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA sTREETADDREss 191 N. First Street MAILING ADDRESS CRY AND ZIP CODE. Sari Jose CA 95 I 13 BRANGH NAME:Downtown Su erior Court PLAINTIFF: American Express National Bank f/k/a American Express Centurion Bank DEFENDANT: Prabu Annamalai, an individual FOR COURT USE ONLY PLO-C-001 ~x DOEs 1 To 20 [ x l COMPLAINT CONTRACT~ AMENDED COMPLAINT (Number)t ~ CROSS-CQNIPLAINT ~ AMENDED CROSS-COMPLAINT (Number)l Jurisdiction (check all that apply): ~x ACTION IS A LIMITED CIVIL CASE Amount demanded ~ does not exceed $10,000 ~X exceeds $10,000 but does not exceed $25,000~ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)~ ACTION IS RECLASSIFIED by this amended complaint or cross-complaint~ from limited to unlimited~ from unlimited to limited CASE NUMBER 1, plaintiff'name or names): American Express National Bank f/k/a American Express Centurion Bank alleges causes of action against defendant* (name or names): Prabu Annamalai, an individual; Does I through 20, inclusive. 2. This pleading, including attachments and exhibits, consists of the following number of pages: 14 3. a. Each plaintiff named above is a competent adult ~x excegt Plainti~ (name)( American Express National Bank f/k/a American Express Centurion Bank (1) ~xa corporation qualified to do business in California (2) ~ an unincorporated entity (describe)( (3) ~ other (specify): b ~ has complied with all licensing requirements as a licensed (specify): c. ~ Information about additional plaintiffs who are not competent adults is shown in Attachment 3c. 4. a. Each defendant named above is a natural person~ except defendant (name)( (1) ~ a business organization, form unknown (2) ~ a corporation (3) ~ an unincorporated entity (describe)( ~ except defendant (name): (1) ~ a business organization, form unknown (2) ~ a corporation (3) ~ an unincorporated entity (describe): b. ~ Plaintiff (name): a. ~ has complied with the fictitious business name laws and is doing business under the fictitious name (specify): (4) ~ a public entity (describe)( (5) ~ other (specify)( (4) ~ a public entity (describe); (5) ~ other (specify):'f this form is used es a crossoomplaint piarntiff means crossoomplainant and defendant means cross defendant Page 1 of 2 Foun Approved for Optional Use Judoist Counol of California PLD-C-001 [Rev January I, 2007) COMPLAINT-Contract Code of Civil Procedure, 5 425 12 l exrsNexrss) Automated cali/orms cuctcta( cauncr( Forms E-FILED 9/23/2020 12:44 PM Clerk of Court Superior Court of CA, County of Santa Clara 20CV371140 Reviewed By: M Vu 20CV371140 SHORT TITLE. AMEX vs. Annamalai, et al. CASE NUMBER PLD-C-001 4. (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. (1) Cx3 Doe defendants (specify Doe numi)ers) 1-10 inclusive were the agents or employees of the named defendants and acted within the scope of that agency or employment. (2) [K Doe defendants(specifyDoenumbers): 11-20, iitclusive arepersonswhosecapacitiesareunknownto plaintiff. c. ~ Information about additional defendants who are not natural persons is contained in Attachment 4c. d ~ Defendants who are joined under Code of Civil Procedure section 382 are (names): 5. ~ Plaintiff is required to comply with a claims statute, and a. ~ has complied with applicable claims statutes, or b. ~ is excused from complying because (specify): 6. C3 This action is subject to Civil Code section 1812.10 Civil Code section 2984.4. 7. This court is the proper court because a. ~ a defendant entered into the contract here. b. ~ a defendant lived here when the contract was entered into. c ~x a defendant lives here now. d. M the contract was to be performed here. e. ~ a defendant is a corporation or unincorporated association and its principal place of business is here. f. ~ real property that is the subject of this action is located here. g. ~ other(specify): 8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): E3 Breach of Contract CX] Common Counts E3 Other (specify): 9. ~ Other allegations: 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. ~x damages of: $ 10,992.42 b. interest on the damages (1) ~ according to proof (2) ~ at the rate of (specify): percent per year from (date)i c. ~ attorney's fees (1)~ of: $ (2) ~ according to proof. d. ~ other (specify)i 11. ~x The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): 7 Date: September I II, 2020 S encerPenuela Es . SBN:324544 OYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) (lf you wish to ven'fy this pleading, affix a venfication.) PLO-C-001 )RaY January 1, 2007) COMPLAINT-Contract Page 2 of 2 LexisAiexis00 Au)emu)ed Carsforrna Judicial Conned/ Forms SHORT TITLE: AMEX vs. Annamalai, et al. CASE NUMBER; PLD-C-001(2) FIRST CAUSE OF ACTION-Common Counts (number) ATTACHMENT TO ~x Complaint ~ Cross - Complaint (Use a separate cause of action form for each cause of action.) CC-1. Plaintiff (name): American Express National Bank f/k/a 2'-unerican Express Centurion Bank alleges that defendant (name)f Prahu Annamalai, an individual; Does I through 20, inclusive. became indebted to ~x plaintiff other (name): a. ~x within the (1) ~x (2) X last four years on an open book account for money due. because an account was stated in writing by and between plaintiff and defendant in which it was agreed that defendant was indebted to plaintiff. b. ~ within the (2) (4) D (6) last ~ twoyears ~ four years for money had and received by defendant for the use and benefit of plaintiff. for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff. the sum of $ the reasonable value. for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff the sum of $ the reasonable value. for money lent by plaintiff to defendant at defendant's request. for money paid, laid out, and expended to or for defendant at defendant's special instance and request. other (speciiy) f CC-2. $ 10,992.42 plus prejudgment interest from (daie): CC-S C3 Plaintiff is entitled to attorney fees by an agreement or a statute of $ according to proof. CC-4. W Other: , which is the reasonable value, is due and unpaid despite plaintiffs demand, according to proof at the rate of percent per year Form Approved fcr optmnal Use Jud oal Counol of Calfomia PLD-C-oof (2) IRev. January 1, 2000] CAUSE OF ACTlON-Common Counts Page 3 of14 Pa e1of1 Code of Civil Procedure, 2 425 12 www coudinfo ca gov Lexrsidexrsdg A of ornate d Cairffornra dudseral Council Forms PLD-C-001(2) SHORT TITLE: AMEX vs. Annamalai, et al. CASE NUMBER: SECOND CAUSE OF ACTION-Common Counts fnumuer) ATTACHMENT TO x Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) CC-1 Plaintiff (name): American Express National Bank f/k/a American Express Centurion Bank alleges that defendant (name): Prabu Annamalai, an individual; Does I through 20, inclusive. became indebted to ~x plaintiff other (name): a. within the last four years (1) on an open book account for money due. (2) ~ because an account was stated in writing by and between plaintiff and defendant in which it was agieed that defendant was indebted to plaintiff. b. x within the last two years x four years (1) for money had and received by defendant for the use and benefit of plaintiff. (2) for work, labor, services and materials rendered at the special instance and request of defendant and for which defendant promised to pay plaintiff. the sum of $ the reasonable value. (3) for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff C] the sum of $ the reasonable value. (4) x for money lent by plaintiff to defendant at defendant's request. (5) ~ for money paid, laid out, and expended to or for defendant at defendant's special instance and request. (6) other (specify): CC-2. $ 10,992.42 plus prejudgment interest from (date): CC-3. Plaintiff is entitled to attorney fees by an agreement or a statute of$ according to proof. , which is the reasonable value, is due and unpaid despite plaintiffs demand, according to proof ~ at the rate of percent per year CC-4. Other: Form Approved for Opt onal Use Judfoal Counol of Calffom a PL 0-0-00 1 (2) [Rex. Janua fr 1, 2009l CAUSE OF ACTION-Common Counts Page 4 of 14 Pa e1of1 Code of Cwll Procedure, lf S25 12 www coudfnfo ca gov LexfsNexfsfi Aufomated Caiffarufa dudfcfal Council Farms EXHIBIT "A"I I “ ” rrrvrenfDliv Dnrrcss Blue Cash Everyday from American Express PRABU ANNAMALAI Closing Date 02/07/20 9 1/9 Account Ending 1007 New Balance Minimum Payment Due Includes the past due amount of $ 1,762 00 Payment Due Date 810,992.42 91,8/72.00 03/04/20¹ Get cash back for eligible purchases when you use the Card. For more details about Rewards, please visit ameiicanexpress.cam/cashb*ckrevrwds Account Summary Late Payment Warning: lf we do not receive your Mimmum Payment Due by the Payment Due Date of 03/04/20, you may have to pay a late fee of up to $ 39.00 and your APRs may be Mcreased to the Penalty APR of 29.99aSL Previous Balance Payments/Credits New Charges Fees Interest Charged $ 10,992 42 -$0.00 +$0.00 +$0.00 +$0.00 Minimum Payment Warning: if you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: New Balance Minimum Payment Due Credit Limit $ 1 0,992/42, $ 1,872.00 $9,900.00 If you make no additional You wig pay ff th balance charges and each month you shown on thrs statement in I ay-. about.. And you will pay an estimated total of... Cash Advance Limit $ 0.00 Only the Minimum Payment Due 21 years $23,934 Days in Bilhng Period: 28 If you would like information about credit counseling services, call 1-888-733-4139. See page 2 for important information about your account. See page 5 for Important Changes to Your Account Terms. See page 7 for Important Information About Your Account Terms. Customer Care 8 Pay by Computeramericanexpress corn/pbc Customer Care 1-888-258-3741 Pay by Phone 1-800-472-9297 L ~ I See page 3 for additional m/ormation. Please refer to the IMPORTANT NOTICES section for any changes to your Account terms and any other communications on pages5-9. Continued on page 3 4 Please fold on the perforation below, detach and return with your paymentu H Payment CouponDo not staple or use paper clips Q Pay by Computer Pay by Phoneamericanexpress.corn/pbc 1-800-472-9297 Account Ending 1007Enter 15 digit account ¹ on all payments. Make check payable to American Express. PRABU ANNAMALAI &m9 i A I.LARA CA 95051-4522 Payment Due Date 03/04/20 New Balance 5'I 0,992.42 Mmimum Payment Due $ 1,872.00 See reverse side for instructions on how to update your address, phone number, or email. liil ii»'i'»'ll»iiih II "IIIII»lrlliil'inillliil'il» AMERICAN EXPRESS PO BOX 0001 LOS ANGELES CA 90096-8000 Amount Enclosed PRABU ANNAMALAI Account Ending 1007 p 2)9 Payments: Your payment must be sent to the payment address shown an your statement and must be received by 5 p m. local time at that address to be credited as of the day it is received. Payments we receive after 5 p m. will not be credned to your Account until the next day. Payments must also. (I) mclude the remittance coupon fram your statement, (2) be made with a smgle check drawn on a US bank and payable in US dollars, or with a negotiable mstrument payable m US dollars and clearable through the US banking system; and (3) mclude your Account number If your payment does not meet all of the above requirements, credmng may be delayed and you may incur late payment fees and additional mterest charges Eiectromc payments must be made through an electronic payment method payable in US dollars and clearable through the US banking system. If we accept payment in a foreign currency, we will convert it into US dollars at a conversion rate that is acceptable to us, unless a particular rate is required by law. Please do not send post-dated checks as they will be deposited upon receipt Any restnctrve language an a payment we accept will have no effect on us without our express pnor wntten approval. We will re- present to your finanaal institution any payment that is returned unpaid. Permission for Electronic Withdrawah(1) When you send a check for payment, you give us permission to electromcagy withdraw your payment from your deposit or other asset account We will process checks electromcagy by transmitting the amount of the check, routing number, account number and check senal number to your finanoal insutution, unless the check is not processable electromcaliy or a less costly process is available When we process your check electronrcagy, your payment may be withdrawn from your deposit or other asset account as soon as the same day we receive your check, and you wgl not receive that cancelled check with your deposit or other Meet account statement. If we cannot collect the funds eiectromcaliy we may issue a draft against your deposit or other asset account for the amount of the check. (2) By usmg Pay By Computer, Pay By Phone or any other electromc payment service of ours, you give us permission to electroni cally withdraw funds from the deposit or other asset account you speafy in the amount you request. Payments using such services of ours received after 8:00 p.m. MST may not be credited until the next day. How We Calculate Your Balancet We use the Average Daily Balance (ADB) method (mciuding new transactions) to calculate the balance on which we charge mterest on your Account. Cail the Customer Care number on page 3 for more information about this balance computation method and how resulting interest charges are determmed. The merhod we use to figure the ADB and imeiesr results m daily compoundmg of interen Paying Interest: Your due date is at least 25 days after the close of each bilk ng period. We will not charge you interest on your purchases if you pay each month your entire balance (or Ad)usted Balance iF apphcabiel by the due date each month. We will charge you interest on cash advances and (unless otherwise disclosed) balance transfers begmning on the transaction date. Foreign Currency Charges: If you make a Charge in a foreign currency, we will convert it mto US dollars on the date we or our agents process it. We will charge a fee of 2.709a of the converted Us dollar amount. We wilt choose a conversion rate that is acceptable to us for that date. unless a particular rate is required by law. The conversion rate we use is no more than the highest offiaal rate published by a government agency or the highest interbank rate we identify from customary bankmg sources an the conversion date or the pnor business day. This rate may differ from rates in effect on the date of your charge. Charges converted by establishments (su«h as airknes) wig be billed at the rates such estabhshments use. Credit Balance: A credit balance (designated CR) shown on this statement represents money owed to you. If within the six-month penod fogowmg the date of the first statement indicating the credit balance you do not request a refund or charge enough to use up the credit balance, we will send you a check for the credit balance withm 30 days if the amount is $ 1.00 or more. Credit Reporting: We may report mformation about your Account to credit bureaus. Late payments, missed payments, or other defaults on your Account may be reflected m your credit report What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement, wnte to us at Amencan Express, PQ Box 981535, El Paso TX 7999B-1535 You may also contact us on the Web. www a manes nexpress corn In your letter, give us the fosowing informauon: - Account information: Your name and account number. - Defer amount: The dollar amount of the suspected error. - Description of Problem: if you thmk there is an error on youi bill, descnbe what you believe is wrong and why you behave it is a mistake You must contact us within 60 days after the error appeared on your statement. You must nobfy us of any potential errors in writmg [or electromcagy) You may call us, but if you do we are not required to mvestigate any potential errors and you may have to pay the amount m question. While we mvestigate whether or not there has been an error, the following are true - We cannot try to collect the amount in questron, or report you as delinquent on that amount - The charge m question may remain on your statement, and we may contmue to charge you interest an that amount. But, if we determine that we made a mistake, you will not have to pay the amount in quesuon or any interest or other fees related to that amount - While you do not have to pay the amount in question, you are responsible for the rema mder of your balance. - We can apply any unpaid amount against your credit hmit Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in goad faith to correct the problem with the merchant, you may have the nght not to pay the remaming amount due on the purchase To use this nght, ag of the foilowmg must be true 1. The purchase must have been made in your home state or within 100 miles of your current maihng address, and the purchase pnce must have been more than $50 (Note Neither of these is necessary if your purchase was based on an adverosement we mailed to you, or if we own the company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify 3. You must not yet have fully paid for the purchase. If all of the critena above are met and you are stilt dissatisfied with the purchase, contact us m wnting or electronicagy ac Amencan Express, PO Box 991535, Ei Paso TX 79998-1535 www.amencanexpress.corn While we mvesbgate, the same rules apply to the disputed amount as discussed above After we finish our invesugation, we will tell you our deosion At that point, iF we thmk you owe an amount and you do not pay we may report you as dehnquent. Pay Your Bill with AutoPay Deduct your payment from your bank account automatically each month. Change of Address, phone number, email Online at www.a meri canexpress.corn fu pdatecontacticdo Via mobile device Voice automated: cail the number an the back of your card For name, company name, and foreign address or phone changes, please cail Customer Care - Avoid late fees - Save bme Visit a.itiencanexpi'ess.cont/autopay today to enroll. Please do not add any written communication or address change on this stub For information on how we protect your pnvacy and to set your communication and privacy choices, please visit www.americanexpress.corn/privacy. xiaemovv wtss Blue Cash Everyday'rom American Express PRABU ANNAMALAI Closing Date 02/07/20 p 3/9 Account Ending 1007 Customer Care & Billing Inquiries8 International Collect Large Print & Braille Statements Cash Advance at ATMs Inquiries 1-888-258-3741 Hearing Impaired 1-336-393-1111 TTY:1-800-221-9950 1-888-258-3741 FAX:1-623-707-4442 1-800-CASH-NOW In NY: 1-800-522-1897 Customer Care 8 Billing Inquiries P.O. BOX 981535 EL PASO, TX 79998-1535 Payments PO BOX 0001 LOS ANGELES CA 90096-8000 Websitei amencanexpress.corn8 Oi This statement is for information purposes only. This is not a bill. Please contact your collections agency for account information. Disregard the Minimum Payment Due, your account is in default and the balance is due in full. QI Did you knowt You can use Plan It to split up large purchases and pay them off over time for a fixed monthly fee and no interest. Plus, still earn rewards on Plan It purchase amounts. Terms apply. Visit airiericanexpl"ess.corri/payltpianiL Fees Amount Total Fees for this Period $0.00 Interest Charged Total Interest Charged for this Period Amount $0.00 About Trailing interest You may see interest on your next statement even if you pay the new balance in fuii and on time and make no new charges. This is called "traikng interest." Trailing interest is the mterest charged when, for example, you didn't pay your previous balance in fuii. When that happens we charge interest from the first day of the bilk ng period until we receive your payment in full. You can avoid paying interest on purchases by paying your balance m full and on ume each month. Please see the "When we charge interest" sub-section in your Cardm ember Agreement for details. 2020 Fees and Interest Totals Year-to-Date 1 otal Fees in 2020 Totalinterestin 2020 Amount $39.00 $ 170.89 Interest Charge Calculation Your Annual Percentage Rate (APRI is the annual interest rate on your account Transactions Dated Annual Percentage From To Rate Balance Subject to Interest Rate Interest Charge Purchases 10/29/2019 18.49r/r (vi $0.00 $ 0.00 Contmued on reverse PRABU ANNAMALAI Account Ending 1007 p 4/9 Interest Charge Calculation Continued Your Annual Percentage Rate (APR) is the annual interest rate on your account. Transactions Dated Annual Percentage From To Rate Balance Subject to interest Rate Interest Charge Cash Advances Total ivi i/aaahte iiaie 10/29/2019 26 74ek ivl 90 00 90 00 $0.00 4exi 9fcsn 5 nne 9 PRABU ANNAMALAI Closing Date 02/07/20 9 5/9 Account Ending 1007 Notice of Important Changes to Your Account Terms We are making changes to your American Express Cardmember Agreement referenced in this notice. We encourage you to read this notice, share it with Additional Card Members on your account, and file it for future reference. The detailed changes to your Cardmember Agreement can be found after the below summary chart. ~ ~ ~ ~ The following is a summary of the changes that are being made to your account terms effective on May 1, 2020. For more detailed information, please see the Detail of Changes to your Cardmember Agreement that can be found on the following page. The late payment fee and returned payment fee will be changed from a maximum of $39 to a maximum of $40. In addition, the first time a payment is not received by the Payment Due Date or returned unpaid by your bank, the fee will now be $29. . RevisedTenns;as'ofnlay112020 Late Payment Fee Up to $40 Returned Payment Fee Up to $40 iD 12934 Please see reverse side for the Detail of Changes to Your Cardmember Agreement. Important Notices centi nued on nexr page. CMLENGDPRUS0066 PRABU ANNAMALAI Closing Date 02/07/20 's" 6 St rs 9 6/9 Account Ending 1007 Detail of Changes to Your Cardmember Agreement This notice amends your American Express Cardmember Agreement (" Agreement" ) as described below. Any terms in the Cardmember Agreement conflicting with this change are completely replaced Terms not changed by this notice continue to apply. If you have any questions, please call the number on the back of your Card. Late Payment Fees and Returned Payment Fees Effective May 1, 2020, the Fees section on page 1 of Part 1 of the Cardmember Agreement is amended by deleting the Late Payment and Return Payment fees under the Penalty Fees subsection and replacing it with the following: Penalty Fees Late Payment Returned Payment Up to $40 Up to $40 Late Payment Fee Effective May 1, 2020, the Fees section on page 2 of Part 1 of the Cardmember Agreement is amended in the Late Payment row by replacing each instance of "$28" with "$29" and replacing each instance of "$ 39" with "$40." Returned Payment Fee Effective May 1, 2020, the Fees section on page 2 of Part 1 of the Cardmember Agreement is amended in the Returned Payment row by replacing each instance of "$28" with "$29" and replacing each instance of "$39" with "$40." Important Notices continued on next page. s xmew!'AN PRAI3U ANNAMALAI Closing Date 02/07/20 a 7/9 Account Ending 1007 Notice of Important Change to Your Cardmember Agreement We are making a change to your American Express Cardmember Agreement referenced in this notice. We encourage you to read this notice, share it with Additional Card Members on your account, and file it for future reference. The detailed change to your Cardmember Agreement can be found after the below summary chart. :.:Sutntnary:of Change, Effectitre:April 1, 202g i Contactless Transactions We are removing the Contactless Transactions section. Although we are removing this language from your Agreement, your Card provides secure transaction technology, including but not limited to contactless technology. ID 12939 Detail of Change to Your Cardmember Agreement This notice amends your American Express Cardmember Agreement ("Agreemenr') as described below. Any terms in the Cardmember Agreement conflicting with these changes are completely replaced. Terms not changed by this notice continue to apply. If you have any questions, please call the number on the back of your Card. Effective April 1, 2020, the Other important information section in Part 2 of the Cardmember Agreement is amended by deleting the Contactless Transactions section. Global Assist Hotline Effective May 1, 2020, we are refreshing the terms and conditions of Global Assist Hotline to better reflect the scope of this benefit for Card Members. We are making no changes to the benefit itself. For full terms and conditions, please visit americanexpress.corn/gaterms. important Notices can tinued on next page. CMLENGDPRUS0080 PRABU ANNAMALAI Claaing Date 02/07/20 p 8/9 Account Ending 1007 Important Notices continued on next page, ALAI los at cc unt di port t oti inue t e. el rxri s PRABU ANNAMALAI Closing Date 02/07/20 n a/9 Account Ending 1007 EFT Error Resolution Notice In Case of Errors or Questions About Your Electronic Transfers Telephone us at 1-800-IPAY-AXP for Pay By Phone questions, at 1-800-528-2122 for Pay By Computer questions, and at 1-800-528/4800 for AutoPay. You may also write us at American Express, Electronic Funds Services, P.O. Box 981531, El Paso TX 79998-1531, or contact online at www.americanexpress.corn/inquirycenter as soon as you can, if you think your statement or receipt is wrong or if you need more information about a transfer on the statement or receipt. We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. 1. Tell us your name and account number lif any). 2. Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information. 3. Tell us the dollar amount of the suspected error. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this, we will credit your account for the amount you think is in error, so that you will have the use of the money dunng the time it takes us to complete our investigation. End of/mportant Notices.