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. REQUESTS FOR ADMISSIONS DIRECTED AT AMERICAN EXPRESS CENTURION BANK The Defendant PAUL ROGERS (Defendant) asks that the Plaintiff AMERICAN EXPRESS CENTURION BANK (Plaintiff) admit the truth of the matter stated in these Requests for Admissions within the time prescribed by the Florida Rules of Civil Procedure. In the event that the Plaintiff objects to a Request(s), please state the grounds for the objection. In the event that the Plaintiff cannot admit or deny the

Request(s), please specify the reason why the Plaintiff cannot admit or deny the Request(s).

In the event that the Plaintiff does not understand the meaning of a word or words, the Plaintiff shall consult Blacks Law Dictionary or in the alternative request clarification from Defendants attorney. REQUESTS Request #1: Response: Exhibit A attached to the Complaint identifies AMERICAN EXPRESS CENTURION BANK as a party to the Cardmember Agreement.

Request #2: Response:

AMERICAN EXPRESS CENTURION BANK loaned PAUL ROGERS U.S. dollars.

Request #3:

AMERICAN EXPRESS CENTURION BANK advanced U.S. dollars to merchants that PAUL ROGERS presented the AMERICAN EXPRESS CENTURION BANK branded credit card as payment.

Response:

Request #4:

The merchants that PAUL ROGERS presented the AMERICAN EXPRESS CENTURION BANK branded credit card as payment created the business records memorializing the transaction(s).

Response:

Request #5: Response:

AMERICAN EXPRESS CENTURION BANK established an account ending in 6-79002 in the name of PAUL ROGERS.
2

Request #6: Response:

AMERICAN EXPRESS CENTURION BANK deposited U.S. dollars into the account described in Request #5 subsequent to the account being established.

Request #7:

Each time PAUL ROGERS used the account described in Request #5, AMERICAN EXPRESS CENTURION BANK would debit the account in an amount equal to the charges placed onto the account.

Response:

Request #8: Response:

The attached copy of Form 424B2 Prospectus is genuine.

Request #9:

AMERICAN EXPRESS CENTURION BANK sold all of its right, title and interest in the receivables (debts) in designated Extended Payment Option credit accounts to American Express Receivables Financing Corporation I, II, III, or IV.

Response:

Request #10:

American Express Receivables Financing Corporation I, II, III, or IV transferred all of its right, title and interest in the receivables (debts) in designated Extended Payment Option credit accounts to American Express Credit Account Master Trust.

Response:

Request #11:

In exchange for the transfer described in Request #9, AMERICAN EXPRESS CENTURION BANK received an amount of U.S. dollars equal to or greater than the amount of the receivables (debt).

Response:

Request #12: Response:

AMERICAN EXPRESS CENTURION BANK used the net proceeds of U.S. dollars described in Request #13 for its general corporate purposes.

Request #13: Response:

AMERICAN EXPRESS CENTURION BANK is the servicer of the American Express Credit Account Master Trust.

Request #14: Response:

The account ending in 6-79002 was sold by AMERICAN EXPRESS CENTURION BANK.

Request #15: Response:

The attached copy of the AMERICAN EXPRESS CREDIT ACCOUNT MASTER TRUST RECEIVABLES PURCHASE AGREEMENT is genuine.

Request #16: Response:

The account ending in 6-79002 was reassigned to AMERICAN EXPRESS CENTURION BANK.
4

Request #17: Response:

The books and records of AMERICAN EXPRESS CENTURION BANK evidence the sale of the receivable arising from the use of account ending 6-79002.

Request #18:

The books and records of AMERICAN EXPRESS CENTURION BANK show that AMERICAN EXPRESS CENTURION BANK suffered legal damages as a result of the default described in paragraph 6 of the Complaint.

Response:

Request #19: Response:

AMERICAN EXPRESS CENTURION BANK suffered legal damages in an amount equal to $5192.03 as a result of the default described in paragraph 6 of the Complaint.

Request #20: Response:

A documents exists evidencing the allegation that the Plaintiff is obligated to pay its attorneys in this case a reasonable fee for their services.

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