Complaint Limited 10K and 25KCal. Super. - 6th Dist.November 23, 2020E-FILED 11/23/2020 12:00 AM Clerk of Court Superior Court of CA, County of Santa Clara 20CV373922 Reviewed By: L. Quach-Marcellana 20CV373922 PLD-C-001 ATTORNEY 0R PARTY WITHOUTATTORNEY (Name, State Bar number, and address): FOR COURTUSE ONLY Marlanna Mlkhalewch, Es . SBN: 325942 MICHAEL & ASSOCIAT S, PC 555 St. Charles Drive, Suite 204, Thousand Oaks, CA 91360 TsLEPHONE No: (805) 379-8505 FAX N0. (Optional): (805) 379-8525 E-MAIL ADDRESS (Optional); ATTORNEY FOR (Name): American Express National Bank f/k/a American Express Centurion Bank SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA sTREET ADDRESS: 191 N. First Street MAluNG ADDRESS: chv AND ZIP comaSan Jose, CA 95 1 13 Bmucu NAME;Downt0wn Superior Court PLAINTIFF: American Express National Bank f/k/a American Express Centuripn Bank . . I _ DEFENDANT: John Vlcente, aka John E Vlcente, an 1nd1v1dual DOES 1 To 20 CONTRACT compLAIN-r D AMENDED COMPLAINT (Number): E cnoss.coMPLA|NT D AMENDED CROSS-COMPLAINT (Number): Jurisdiction (check all that apply): I ACTION Is A LIMITED cuvu. CASE CASE "UMBER- Amount demanded 2:, does not exceed $10,000 X ' exceeds $10,000 but does not exceed $25,000 ‘ I ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) ‘ I ACTION IS RECLASSFFIED by this amended compiaint or cross-complaint ijrom limited to unlimited E] from unlimited to limited 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): John Vicente, aka John E Vicente, an individual; Does 1 to 20. This pieading, incIuding attachments and exhibits, consists of the following number of pages: 12 3. a. Each piaintiff named above is a competent adult except P'ainfifi (name): American Express National Bank f/k/a American Express Centurion Bank (1) -a corporation quaiified to do business in California (2) Ejan unincorporated entity (describe): (3) mother (specify): 5° b. EjPlaintiff (name): a. [:3 has complied with the fictitious business name laws and is doing business under the fictitious name (specify).- b- E: has complied with ail iicensing requirements as a licensed (speciM: c. [:3 Information about additionai plaintiffs who are not competent adults is shown in Attachment 30. 4. a. Each defendant named above is a natural perSOn E: except defendant (name): E except defendant (name): (1) a a business organization, form unknown (1) E] a business organization, form unknown (2) E: a corporation (2) E3 a corporation (3) [:3 an unincorporated entity (describe): (3)m an unincorporated entity (describe): (4) [j a public entity (describe): (4) [:1 a public entity (describe): (5) E] other (specify): (5)m other (specify): ‘ If this form is used as a crcss-complaim. plaintiff means cross-complainant and defendant means cross-delendant. Page 1 of 2 Form A ed for 0 t’onal U Judicgguncnofga'mamiase COMPLA'NTWOHtFaCt Code oICiviI Procedure. 5425.12 PLD£001 [Rev‘ January 1, 2007} LexisNexis® Automated Calyorm'a Judicial Council Forms PLD-C-001 SHORT TITLE: CASE NUMBER AMEX vs. Vicente, et a1. 4‘ (Continued) b. The true names of defendants sued as Does are unknown_ to plaiptiff. (1) Doe defendants (specify Doe numbers): 1-10, Incluswe defendants and acted within the scope of that agency or employment. (2) Doe defendants (specify Doe numbers): 1 1'20, inCIUSiVC are persons whose capacities are unknown to plaintiff. were the agents 0r employees ofthe named CA D Information about additional defendants who are not natural persons is contained in Attachment 4c d_ D Defendants who are joined under Code 0f Civil Procedure section 382 are (names): 5. D Plaintiff Es required to comply with a claims statute, and a. D has complied with applicable claims statutes, 0r b. E is excused from complying because (specify): 6. [:1 This action is subject to E Civil Code section 1812.10 [j Civil Code section 29844. 7. This court is the proper court because . E a defendant entered intothe contract here. . E a defendant lived here when the contract was entered into. , a defendant lives here now. _ D the contract was to be performed here. m D a defendant is a corporation or unincorporated association and its principal ptace of business is here.E real property that is the subject of this action is located here.E other (specify): O-thOU 8. The foHowing causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): E Breach of Contract Common Counts D Other (specify): 9. E Otherallegations: 10. Plaintiff prays forjudgment for costs of suit; for such relief as is fair. just, and equitable; and for a. damagesof: $ 16,481.57 bV D interestonthe damages (1)E according to proof (2) E] at the rate of (specify): percent per year from (date): c, E attorney‘s fees (1):] of: $ (2)m according to proof, d. D other(specify): 11, The paragraphs of this pEeading afieged on information and belief are as follows (speci agraph numbers): 7 Date: November WC , 2020 J,Marianna Mikhalevich‘ Esq. SBN: 325942 } (TYPE 0R PRINT NAME) (SIGNATuRé’ofi' PLAINTIFF 0R ATTORNEY) (If you wish to ven’fy this pleading, affix a verification.) COMPLAINT-ContractPLD~C-OO1 [Rev January 1‘ 2007] Page 2 of 2 LexissVexi5® A utomaled California Judicial Council Forms PLD-cmuz) SHORT TITLE: CASE NUMBER: AMEX VS. Vicente, ct al. FIRST CAUSE OF ACTION-Common Counts (number) ATTACHMENT TO Complaint [j Cross-Compiaint (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 défendam (name)? John Vicente, aka John E Vicente, an individual; Does 1 t0 20. became indebtedto plaintiff E] other(name): av 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 agreed that defendant was indebted to plaintiff. b‘ E] within the last E two years D four years (1) E for money had and received by defendant for the use and benefit of piaintiff. (2) D for work, labor. services and materials rendered at the special instance and request of defendant . and for which defendant promised to pay plaintiff‘D the sum of $E the reasonable value. (3) E for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff E] the sum of$D the reasonable value. (4) E for money lent by plaintiff to defendant at defendant's request. (5) [:3 for money paid, laid out, and expended to or for defendant at defendant's special instance and request. (6) E] other (specify): CC-2, $ 16,48 1 ,57 ,which is the reasonable value, is due and unpaid despite plaintiff's demand, pEus prejudgment interest m according to proof E at the rate of percent per year from (date): CC-3. E] Plaintiff is entitled to attorney fees by an agreement or a statuteE of$ E] accordingto proof CC-4‘ E] Other: Page 3 of 12 Page 1 of1 Form Approved for Ophonal Use CAUSE 0F ACTION_Comm°n Counts Code of Civil Procedure, § 425 12Judic‘al Councii of Calrfornia vwvw court/nfocavgov PLD-C-OO1(2) [Rev. January 1, 2009] LexisNex-isifil A utomaled Calg'fomia Judicial Counci! Forms PLD-C-001 (2) SHORT TETLE: CASE NUMBER: AMEX vs. Vicente, et a1. SECOND CAUSE 0F ACTION-Common Counts (num ber) ATTACHMENT TO Complaint E Cross-Complaint (Use a separate cause of action form for each cause ofactionl) CC-f Plaintiff (name): American Express National Bank f/k/a American Express Centurion Bank alleges that defendant (name}f John Vicente, aka John E Vicente, an individual; Does 1 t0 20. became indebtedto plaintiff D othermame): a. E within the last four years (1) D on an open book account for money due. (2) E 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 last [j two years four years (1) [:3 for money had and received by defendant for the use and benefit of piaintiff, (2) [:j for work, Eabor, services and materials rendered a1 the special instance and request of defendant ' and for which defendant promised to pay piaintiff. » I [:3 the sum of $ 'E the reasonable value‘ (3) E for goods, wares, and merchandise sold and delivered to defendant and for which defendant promised to pay plaintiff E] the sum of $ E] the reasonable value (4) for money lent by plaintiffto defendant at defendant's request. (5) D for money paid, laid out, and expended to or for defendant at defendant's special instancg and request ‘ (6) E other (specify); o CC-2. $ 16,481 ,57 ,which is the reasonable value, is due and unpaid despite plaintiff's demand, plus prejudgment interest E according to proof D at the rate of percent per year from (date): CC-3. D Plaintiff is entitled to attorney fees by an agreement or a statuteE of$ E1 accordingto proof; cc-4‘ [:1 Other: Page 40.11;. Page 1 of 1 Form Approved for opnonal Use CAUSE OF AcTIONWCommon Counts Code of CMI Procedure § 425.12Judicnal Council of Cahfomna www courtmfocavgov PLD-C-OO1(2) [Rev. January 1, 2009] LexisNexist! Automated Czt1{f0rnia Judiczul Council Forms EXHIBIT “A” Blue from American Express® p 1/7 JOHN VICENTE Ciosing Date 05/26/20 Account Ending .4008 _ ”hm", _, n , “v, , :3 Visit E : New Balance $16,481.57 ‘ g H H . ‘ 3 ' Minimum Payment Due $3,675.00 ‘ ; j i Includes the past due amount of $346600 ‘ ‘ I }t ‘ ' LYNN.“ _,-.,,,, ,flWfiw. mm”... . ??}{???th 999,9?5' mi , , . 95(29/39,, , I Account Summary i Late Payment Warning: If we do not receive your Minimum Payment Due by 3 PFEViOUS Ba‘ance $1 5'48‘ 57 1 the Payment Due Date of 06/20/20, you may have t0 pay a fate fee of up to g ; Payments/Credits ~$0.00 [ $40.00 and your APRs may be increased to the Penalty APR of 29.24% 1 New Charges +$0.00 l g ‘ Fees +5000 Interest Charged +$0.00 Minimum Payment Warning: If you make only the minimum payment each period, l ‘ ”?V‘f Balance “543157 1 you wiH pay more in interest and it will take you longer to pay off your balance. For ‘ v Minimum Paymem Due $3,675-00 1 Jexample: 3‘ H r w w r ~ ~~l , ,,,,,,, ,H V , , ,,_,,,,,VW,, M ,W, ,,,,, V __ CreditLimit $15,100‘OO 1 Ifyou make no additional You wiil pay offthe balance And you will pay an ‘ I 1 . 4 . ‘a:arges and each month you :ggwtn on Ihls statement m estimated total of... i Cash Advance Limit $0.00 3p y... u i ‘ 1 Onl the i . . . . I 3 Minimum Péymem Due 24 years $34,154 1 Y Days In Bilimg Period. 32 i ‘7 r r H fl \ “.MA _ lfyou would like information about credit counseling serwces, cal} 1‘888733'4139. 91%fi9tpfirg . a . .fi .Wi i,‘-W fl Pay by Computer \ x . . V 1 b3 See page 2 for Important Information about your account. americanexpress‘com/pbc l Customer Care Pay by PhonePiease refer to the WIPORTANT NOTECES section for any changes t0 }_888_258_3741 1.800.472.9297 your Account terms and any other communications on ‘ ._ j $33995 5 “ 7- ‘ L-fl See page 3 for additional information. ‘ ® This statement is for information purposes oniy. 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. 4: Please fold 0n the perforation below, detach and return with your payment-L a Payment Coupon Pay by Computer r Pay by Phone Account Ending 4008Do not staple or use paper clips americanexpresscom/pbc }~800A472~9297 Enter 15 digit account 3: on all payments. Make Check payabie to American Express. ulIIll“itllulIIIlilnlliIlllmluliirlnlnlllaEnlllllnllu JOHNVICENTE Payment Due Date . 06/20/20 SAN JOSE CA 95133-1803 Ne Bala Cw n e $16,481.57 Minimum Pa ment Due 3,675.00 "I'll“I'Ih'nmglHII'W'I'IIIIn'lI‘il'I'II'-'|""Ili"nl See reverse side forinstructions AMEWCAN EXPRESS ' 5mm. on how to update your address, PO BOX 000] Amount Enclosed phone number, or email. LOS ANGELES CA 900968000 JOHN VICENTE Payments: Your payment must be sent {o the payment address Shown on your statement ané must be received by S pm. Eoca} time at that address to be cyedited as of the day it is received. Payments we receive after 5 pm. will not be credited to your Account until the next day. Payments must a‘so. (1} inciude the remittance coupon from your statement,- (2) be made with a single check drawn on a US bank and payable in US dollars, or with a negotiable instrument payabie in US doHars and clearaifie through the US banking system; and {3) include your Account number. if your payment does not meet ail of the above requirements, crediting may be deJayed and you may incur late payment fees and additional interest charge; Electron‘rc payments must be made through an electronic payment method payable in US dollars and dearable through the US banking system. If we accepI payment in a foreign currency, we will convert it into US doiiars at a conversion rate that is acceptable to us, unless a panicuiar rate is reqwred by taw. Please do not send post‘dated checks as they will be deposited upon receipt. Any restrictive language on a payment we accept wilt have no effect on us w‘mhout our express prior written approval. We wiEt re~ pfesent to your financgat institution any payment that is returned unpaid. Permission for Eiectronic Withdrawalfl} When you send a Check for payment. you give us permission to eiectronically withdraw your payment from your deposit or other asset accomt. We will process checks electronically by transmitting the amount of the check. routing numben account number and check serial number to your financial institution, unEess the check '15 not processable eiectronicaliy or a less costly process is avaliabfe. When we process your check eiecnonically your payment may be withdrawn from your deposit or other asset account as soon as the same day we receive your check, and you wiH not receive that cancelied check with your deposit 0r other asset account statement 1f we cannot collect the funds efectronicaily We may issue a draft against your deposit 0r other asset account for the amount of the check. (2) By using ?ay By Computer, Pay By Phone or any other eEectronic paymem service of ours, you give us permission to electronicaily withdraw funds from the depdsit or other asset account you specify in the amount you request. Payments‘using'sqch services of ours {eceived after 8:00 pm. MST may not be credited until the next day. How We Calculate Your Balance: We use the Average Daliy Baiance (ADE) method (including new transactions) to caiculate the balance on which we charge interest on your Account. Caii the Customer Care number on page 3 for more information about this balance computation method and how resulting interest charges are determmedV The method we use to figure the ADB and interest results in daiiy compounding ofinreresr. ?aying Interesthour due date is at least 25 clays after the close of each bitling period We will not charge you interest on your pulchases if you pay each month your entire balance (or Adjusted Balance if appficable} by the due date each month. We will charge you interest on cash advances and (unless otherwise disciosed) baiance transfers beginning on the transaction date. ‘ Foreign Currency Charges: If you make a Charge in a foreign currency, we will convert it into US dollars on the date we 0r our agents proces‘s iL We will charge a fee of 2.70% of the converted US dollar amount. We wiII choose a conversion rate that is acceptable to us for that date. uniess a particular rate 55 required by iaw. The conversion rate we use is no mor'e than the highest official rate published by a government agency or the highest interbank rate we identify from customary banking sources on the conversion date or the prior business day. This rate may differ from rates in effect on the date of your charge Charges converted by estabtishments (such as airlEnes) wiii be biEled at the rates such establishments use. Change of Address, phone number, emaii‘ fCs - Ontine at "swwwqanwricamxpmmccmlupdgiemmafii - Via mobile device - Voice automated: calf the number on the back of your card w - For name, company name, and foreign address or phone Changes; p Please do not add any written communication or address change on this stub 6969970? Ending ‘ Jease caiE Customer Care 4008 p‘ 217 Credit Balance: A credit balance (designated CR) shown on this statement Ieplesents money owed t0 you. ff within the six-momh period following the date of the first statement inéicating the credit balance you do no: request a Iefund or charge enough to use up the credit balance, we will send you a check for the credit baiance within 3O days If the amount is $100 or more. Credit Reporting: We may report information about your Account to credit bureaus. Late payments. missed payments, or other defauEts on your Account may be reflected in your credit report. What To Do IfYou Think You Find A Mistake On Your Statement hf you think there 'rs an error on your statement, write Io us at: American Express, PO Box 981535, El Paso TX ?99984 535 You may also contact us on the Web: www.americanexpressxorn In your ietter, give us the following information: ~ Account information: Your name and account number, - Dollar amount:The doHar amount of the suspected error. - Description of Problem: lfyou think there is an error on your bill, descu’be what you believe is wrong and why you believe 3t is a mistake. You must contact us within 60 days after the error appeared on your statément. You must notify us of any potentiai errors En writing {or electronécally], You may call us, but ifyou do we are not required t0 investigate any potentiaE errors and you may have to pay the amount in question. Whfie we investigate whether or not there has been an error, the following are true: - We cannot try to collect the amount m question, or report you as delinquent on {hm amount. - The charge in questéon may remain on your statement] and we may continue to charge you interest on that amount But, if we determine that we made a mistake, you will not have to pay the amount in question or any intelest or other fees related to that amount. » While you do not have to pay the amount in question, you are responsible for the remainder of your ba‘ance. - We can appiy any unpaid amount against your credit limit. Youi' Rights lfYou Are Dissatisfied With You: Credit Catd Purchases Sf yOu are drssatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the {emaining amount due 0n the purchase. To use this right, all ofthe foifiowing must be true: L The punchase must have been made in your home state orwithén 100 males ofyour current mailing address, and the purchase price must have beenmoré than $50. (Note: Neither of these i5 necessary if you: purchase was‘ based on an advertisement we mailed to you. or if we own the company‘that 503d you the goods or services.) 2. You must have used you! credit card for the purchase. Purchases made with éaSh ’aduances from an ATM or with a check that accesses your credit card account do not aualify. 3. Ybu mus! not yet have quy paid for the purchase. If all of’th‘e criieria above are met and you are inEI dissatisfied with the purchase, contact us 1n writing or electronically at: Amerécan Express, PO Box 981 S35, El Paso TX 799984535 www.emericanexpress.com Whne we investigate, the same ruies apply to the disputed amount as discussed above. After we finish our investigation! we will teit you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent, Pay Your Bil! with AutoPay \ x 1 Deduct your paymentfrom your bank Eaccount automatically each month. - Avoid late fees ~ Save time r isit ameritsnaxgresgxomiauwpay lw 3 trodayto enroil. g V7 ; \ For information on how we protect your pfévacy and to set you! communication and privacy choices, please visit www.americanexpressmomlprivacy. JOHN VICENTE Ciosing Date 05/26/20 Customer Care 81 Billing Inquiries i International Collect Large Print & Braille S‘atements Cash Advance at ATMs Inquiries Blue from American Express® 1~888-BLUE~741 18832583741 1-336-393-1 1 H 1~888~8LUE~741 1~888r258-3741 Hearing Impaired TTY: 1-800-22179950 FAX: 1623-7074442 In NY: 1-800-5224897 T‘SOO-CASH-NOW p. 3/7 Account Ending 4008 Customer Care & Billing Inquiries P.O. BOX 981535 EL PASO, TX 79998-1535 Website: americanexpresscom Payments PO BOX 0001 LOS ANGELES CA 900968000 r, gFees Amount Total Fees for this ??fiod 7 W 7 7 W $0.00 § interest Charged E \ Amount Tfiotrglilnrterest Charged for this Period“ $0419 7 About Trailing Interest You may see interest on your next statement even ifyou pay the new baiance in full and on time and make no new charges. This is cailed “trailing interest“ Traiiing interest is the interest charged when, for exampie, you didn‘t pay your previous balance in full‘ When that happens we charge interest from the first day ofthe biHing period until we receive your payment in fufl‘ You can avoid paying interest on purchases by paying your balance in full and on time each month‘ Pfease see the "When we charge interest” sub-section 1n your Cardmember Agreement for details. 2020 Fees and Interest Totals Year-to-Date 4 g g Amount g Total Fees in 2020 $156.00 3 Total Interest an 2020 311520.06 1 i i § Interest Charge Calculation 1‘ 3 Your Annuai Percentage Rate (APR) is the annuai interest rate 0n your account Transactions Dated Annual Balance Interest Percentage Subject to Charge From To H Rate Ingelggt Rate Purchases 10/14/201 6 29.24% (v) $0.00 $0.00 Cash Advances 10/14/2016 29.24% (V) $0.00 $0.00 Total K 7 $0.00 (v) Variable Rate JOHN VICENTE Account Ending 4008 p‘ 4/7 p 5/7 J_O’H VICENTE Closing Date 05/26/20 Account Ending 4-1008 Notice of Important Changes to Your Cardmember Agreement 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 fiie it for future reference. The detailed changes to your Cardmember Agreement can be found after the below summary chart Summary of Changes, Effective for Biliing Periods ending on or after August 1, 2020 How we caiculate We are changing how we cakculate your Minimum Payment Due. As a your Minimum result, your Minimum Payment Due may be higher, lfyou are in a payment Payment Due program, your program enrollment wilf not be affected by this change and this change will become effective for you upon comptetion ofyour payment program. lf you are enrolied m Autopay and selected Fixed Amoun: as your payment setting, please {eview the amount you chose, as it may now be less than your Minimum Paymem Due. ID 13001 See the following page for the Detail of Changes to your Cardmember Agreement. ImportantNoricesrcontmued on next page. CMLENGWWUSOOSB Detail of Change 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. [f you have any questions, please call the number on the back of your Card. About Your Minimum Payment Due Effective for billing periods ending on or after August 1, 2020, Part 2 of the Cardmember Agreement is amended by deleting the How we calculate your Minimum Payment Due section and replacing it with the following: How we calculate your Minimum Payment Due To calculate the Minimum Payment Due for each billing statement, we start with the highest 0f; (1) Interest charged on the billing statement plus 1% ofthe New Balance (exciuding any interest, penalty fees, overlimit amount, and plan balances); or (2) 2% of the New Balance (excluding any penalty fees, overlimit amount, and plan balances); or (3 ) $40. Then we add any penalty fees shown on the billing statement, up to 1/24th of any overlimit amount, any plan payment due, and any amount past due. Your Minimum Payment Due will not exceed your New Balance. You may pay more than the Minimum Payment Due, up to your New Balance, at any time. EXAMPLE: Assume ihat your New Balance is - - $2 900, interestis $29 57 and you have no active plans oveflimit amount penalty fees or amounts past due (1) $29 57 + 1% mu/tip/ied by ($2 900 $29. 57)-w $58 27 j ‘ (2) $58 (2% of$2 900) (3) $40 ‘ The highest of (1), (2) or (3) is $58.27 lfyouikaccount has any active plans oveflimit amount, penalty fees or amounts past due your Minimum Payment Due will be highel. Important Notices continued on next page. p. 7/7 JOHN VICENTE Ciosing Date 05/26/20 Account Ending £4008 EF‘?‘ Ermr Ressautian f‘émfice In Case 0f Errors or Questions About Your Electronic Transfers Telephone us at 1-800-lPAY-AXP for Pay By Phone questions, at I-800~528w21 22 for Pay By Computer questions, and at ¥800-528»4800 for AutoPay. You may also write us at American Express, Electronic Funds Services, PO. Box 981531, Ei Paso TX 799984531, or contact online at www.americanexpress.com/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 n0 later than 60 days after we sent you the FIRST staiement on which the eyror 0r problem appeared 1.Te|| us your name and account number (Efany). 2. Describe the error or the transfer you are unsure about, and explain as dearly 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 wii} investigate your compiaint and will correct any error promptly. If we take more than 1O business days to do this, we wii| credit your account for the amount you think is in error, so that you will have the use of the money during the time it takes us to complete our investigation. End offmportanr Notices.