IN THE COUNTY COURT FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO.

: 50 2011 CC 005699XXXXMB (RB) AMERICAN EXPRESS CENTURION BANK, Plaintiff, -vsPAUL ROGERS, Defendant. FIRST SET OF INTERROGATORIES DIRECTED AT AMERICAN EXPRESS CENTURION BANK The Defendant PAUL ROGERS (“Defendant”) asks that the Plaintiff AMERICAN EXPRESS CENTURION BANK (“Plaintiff”) answer each interrogatory fully and separately. The interrogatories must be signed by the

person answering them and verified or affirmed. In the event that an objection to an interrogatory is made, the grounds of the objection must be given instead of an answer. The objection must be as specific as an objection to evidence at trial. In the event that the Plaintiff does not understand the meaning of a word or words, the Plaintiff shall consult Black’s Law Dictionary, or in the alternative, request clarification from Defendant’s attorney.

INTERROGATORIES 1. What is your name and address?
2. What initial disclosures were given to the Defendant prior to the account

ending in 6-79002 being established? 3. Were these initial disclosures in writing? 4. If the answer to Interrogatory #3 is yes, what is the name and address of the records custodian maintaining the disclosures? 5. On what date were these disclosures given to the Defendant? 6. What is the name and address of the person having knowledge of the initial disclosures given to the Defendant?
7.

Did the Defendant execute any document prior to the account ending in 6-79002 being established?

8. What is the name and address of the records custodian maintaining the

document? 9. Did the Plaintiff deposit U.S. dollars into the account ending in 6-79002? 10.If the answer to Interrogatory #9 is yes, what amount of U.S. dollars was deposited?

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11. Identify the source of the U.S. dollars deposited into the account

including the account number that was debited in order to credit account ending in 6-79002. 12.If the answer to Interrogatory #9 is no, what was deposited into the account? 13.If the Defendant presented the plastic card bearing account number ending in 6-79002 to a merchant of goods, services or labor for payment, explain why the Defendant is indebted to the Plaintiff if the merchants accept the plastic card as payment.
14. If the Plaintiff contends that it loaned the Defendant U.S. dollars state the

dates of the loans, the amounts of the loans, and the instruments used to transfer the U.S. dollars, such as a negotiable instruments, Federal Reserve Notes, ACH credit order, electronic wire transfer, etc. 15.If your answer to Interrogatory #14 was yes, were the loans evidenced in writing? If yes, identify the name and address of the records custodian maintaining the writing.
16. If the Plaintiff contends that it advanced U.S. dollars to merchants that

accepted the plastic card bearing account number ending 6-79002 as a method of payment, identify the dates of advances, the amounts of the advances and the instruments used to transfer the U.S. dollars, such as a negotiable instruments, Federal Reserve Notes, ACH credit orders, electronic wire transfers, etc. 17.If your answer to Interrogatory #16 was yes, were the advances evidenced in writing? If yes, identify the name and address of the records custodian maintaining the writing.

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18. Identify the name and address of the persons having knowledge of the

financial transactions identified in Interrogatories #14 and #16. 19.Did the Plaintiff sell the receivable(s) arising from the Defendant’s alleged use of account number ending 6-79002? 20.If the answer to Interrogatory #19 is yes, what was the amount of U.S. dollars the Plaintiff received as a result of the sale? 21.If the answer to Interrogatory #19 is yes, explain how the Plaintiff suffered legal damages as a result of the default described in paragraph 6 of the Complaint.
22. Identify the amount of the fees the Plaintiff is obligated to pay its

attorneys as is alleged in paragraph 9 of the Plaintiff’s Complaint.
VERIFICATION I have read the foregoing answers to the interrogatories propounded on Plaintiff on this day of , 2011, and hereby acknowledge that they are true . By: Print Name Dated: COUNTY OF STATE OF ) ) ss )

and correct and to the best information available to:

The foregoing instrument was acknowledged before me, a person authorized to take oaths and affirmations, this day of , 2011, by , who is personally known to me or who produced 4

as identification, and who took an oath and swore that the foregoing was true and correct to the best of his/her knowledge. NOTARY PUBLIC My Commission Expires:

I certify that a copy of the foregoing was furnished by first class mail to: Brandon A. Stanko, 10550 Deerwood Park Boulevard, Suite 300 Jacksonville, FL 32256 on Dated: , 2011. The Delta Law Firm HOWARD FEINMEL, ESQUIRE FBN: 169293 Attorney for the Plaintiff 5030 Champion Blvd. PMB #G6-275 Boca Raton, FL 33496 Telephone 561-910-5985

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