Legal Document: Satish Sandadi vs. Surinder PAL Goswamy, et al

On December 16, 2021 a Plaintiff_declaration_op_MSADJ_Exhibit1_Jul19 was filed involving a dispute between Sandadi, Satish, and Does 1 Through 5, Goswamy, Surinder Pal, for (06) Unlimited Breach of Contract/Warranty in the District Court of San Mateo County.

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Satish Sandadi, In Pro Per
606 Dromana Ct
San Ramon, CA 94582
(408) 832-1495 (Tel)
Self-Represented

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
MAIN SOUTHERN COURTHOUSE

10 Case No: 21-CIV-06653
11
PLAINTIFF SATISH SANDADI’S
12
Satish SANDADI, DECLARATION IN SUPPORT OF THE
13 Plaintiff(s), OPPOSITION TO DEFENDANT
14
SURINDER PAL GOSWAMY’S
vs. MOTION FOR SUMMARY JUDGMENT
15 OR ALTERNATIVELY SUMMARY
16 Surinder Pal GOSWAMY, and Does ADJUDICATION.
17 1-10,
Dept. 24
18 Defendant(s), Hon. Judge Jeffrey R Finnigan
Date: Jul 19, 2024
19
Trail Date: Nov 18, 2024
20

22 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
23 PLEASE TAKE NOTICE
24
I, Satish R Sandadi, declare as follows.

26
1) Lam the plaintiff in the above matter and over 18 years of age.
27 2) Isubmit this declaration in support of my response to Defendant’s Motion to Summary
28 Judgement or alternatively summary adjudication.
3) IDECLARE that under penalty of perjury under the laws of the State of California that
the foregoing and following is true and correct.

21-CIV-06653 Sandadi v. Goswamy
DOWN PAYMENT AND EQUITY

Satish Sandadi and Surinder Pal Goswamy bought the property in November 2015. The down
payment was provided solely from Plaintiff's funds. The total amount invested by the Plaintiff
was between $565,000 - $570,000. Bank and Escrow closing statements from 2015 are

attached as Exhibit One - Bank and Escrow Statements. Defendant provided proof of funds
around the time of purchase, for his share of the down payment, but did not provide any actual
funds for purchase.

10
RENT ISSUE
11
12 The property was rented, as rental income, from December 2015 to June 2016. The monthly

13 rental income was $2995.00. Defendant did not put these funds into the working capital of the
14 partnership nor provided any accounting of its distributions until after the filing of this lawsuit.
15 The total cumulative rent collected was around $20,000. Defendant failed to provide an
16 accounting of the funds received. Defendant failed to provide any net accounting after any
17
necessary expenses or costs, i.e., broken window or torn carpet. Additionally, Defendant
18
refunded to a tenant the rent deposit check from the LLC checking account. Documentation is
19
enclosed. This additional amount raises the sum to $22,000. Plaintiff is seeking 50% of this
20
amount. The Defendant’s contention that the statute of limitations bars the rent claim. However,
21
Defendant failed to file LLC taxes for both tax years 2016 and 2017 until August of 2018.
22
Additionally, tax debts remain outstanding through to 2022; and no accounting was done prior
23
to that other than a profit and loss expense sheet in February 2017. See Exhibit Two - Rent
24
Documents.
25

26
CONSTRUCTION LOAN AND DRAWS
27

28 Defendant spent roughly between $250K-270K progressively until Feb of 2017 when we were
approved for a construction loan from Heritage Bank of Commerce. Upon construction loan
approval, the Defendant tried to withdraw his initial and limited investment amount without
Plaintiff's knowledge. Emails and bank draw documentation enclosed. Exhibit Three-
Construction Loan Details.

21-CIV-06653 Sandadi v. Goswamy
Defendant threatened Plaintiff that he was going to stop on-going construction unless Plaintiff
complied with Defendant’s withdrawal request. Plaintiff has the voicemail from Defendant as
additional evidence which can be brought up in trial.

As a compromise Plaintiff received $150,000 from the first construction draw. So, Plaintiff's

investment amount is reduced to a subtotal of $415,000. Defendant’s investment is still at less

than $275,000.

10
TAXES

11 The 2016 LLC tax filing was due in March 2017. Defendant neither paid the minimum CA
12
franchise tax board fee of $800 or filed the tax returns for 2016 until August of 2018. Plaintiff
13
asked the Defendant repeatedly to timely file 2016 partnership returns. As these taxes are still
14
unresolved and owed, the issue remains before the Court and thus should be allowed to go to
15
trial.
16

17
After the sale of the property in December 2017, Plaintiff repeatedly asked Defendant to provide
18
accounting and file LLC partnership returns for 2016 and 2017. Instead, Defendant told
19

20
Plaintiff to file on his own. Plaintiff consulted a CPA to file and pay a share of partnership K-

21 1’s. Plaintiff's accountant said that parties need to file joint returns for 2016 and 2017. Thus,

22 Plaintiff was unable to file separately. The 2017 CA minimum tax fee of $800 for LLC was
23 not paid either.
24

25 Finally, taxes were filed in August 2018, and Defendant gave Plaintiff a copy of the 2017
26 partnership K-1 and CA tax voucher for Plaintiffto pay. The plaintiff refused to pay and asked
27
to settle the accounting first. Plaintiff was willing to pay a share of the tax bill once the
28
accounting was settled.

Defendant continued to receive LLC tax notices at his home or business addresses from both
California Franchise Tax Board and IRS.

21-CIV-06653 Sandadi v. Goswamy
As the time passed and as the single member LLC was active the CA Franchise Tax Board
levied and collected $9,800.00 from LLC checking account for late filing penalties, 2016 and
2017 unpaid minimum taxes and taxes on gross sale amount of the property in 2017.

The IRS continued to send tax notices to the Defendant’s address until 2020. Once the IRS got
Plaintiff's mailing address updated in their system from Plaintiff's LLC 2018 tax returns, they
started sending tax notices to Plaintiff. Plaintiff appealed the late filing penalties for 2016 and
2017. The IRS declined to consider any requests under the appeal. Documentation is provided

10 for the correspondence between Plaintiff and IRS. The total amount owed is $8,600. Right

11 now, Plaintiff is paying this outstanding bill in installments to the IRS starting in 2022 under a
12 4-year payment plan.
13

14 The single member LLC was finally terminated in December of 2019. Exhibit Four Tax
15 documents.
16

18 CONCLUSION
The parties mutually entered a business transaction to buy and sell a rental property. Defendant
19

20
presented to be trustworthy. Plaintiff trusted Defendant and operated under the LLC but

21 accepted that as enough of a contract between parties. Plaintiff, in good faith, provided front

22 money and trusted in an even division of net proceeds. Defendant acted in self-interest by not
23 providing accounting, not paying taxes, moving funds from the LLC account to a private
24 account, and more. Thereby, Defendant enjoyed unjust enrichment by taking more profits
25 despite investing less than Plaintiff. Defendant kept the rental income without accounting or
26 sharing. Taxes were not filed timely. Defendant’s withdrawal from LLC does not absolve him
27
in filing timely tax returns or paying his share of the taxes owed for the period (2016-2017)
28
while he was a member.

Plaintiff followed up with Defendant several times through phone calls, text, and emails but he
did not respond. On one occasion, Plaintiff went to Defendant’s house to ask him to pay the
IRS bill a week before filing this lawsuit. Defendant simply ignored Plaintiff. At one point,
Plaintiff would have been content if Defendant had merely paid the outstanding IRS tax bill.

21-CIV-06653 Sandadi v. Goswamy
Defendant argues that funds were distributed equally in escrow but how did Plaintiff end up
getting an extra $47,000 as distribution? This also is an issue that is triable before the Court.
That’s because of Plaintiff's excess equity in the partnership and it’s still short. In addition, the
Defendant’s lack of equal equity contribution increased costs for the project in more interest
charges and unnecessary expenses.

On top of LLC taxes, Plaintiff also suffered penalties and interest for late filing on Plaintiff's

10 personal tax returns due to having to wait agonizingly for the LLC partnership returns to merge

11 into Plaintiff's personal tax returns.
12

13 It would be a travesty of justice if the lawsuit does not go to trial. Please don’t punish people
14 like me who were sincere and honest in their dealings. Otherwise, it will motivate people to
15 start companies, commit misdeeds, mismanage funds, and escape the consequences. Plaintiff
16
would have filed this lawsuit much earlier if COVID-19 was not affecting our lives and it was
17
still filed before the statutes expired.
18

19 I DECLARE that under the penalty of perjury under the laws of the State of California the
20 foregoing and following is true and correct.
21

22 EXHIBIT(S).
23
Bank and Escrow Documents
24 Rent Documents
Construction Loan details
Tax Documents
26

Date June 30, 2024
Satish Sandadi, Plaintiff
\

21-CIV-06653 Sandadi v. Goswamy
10

11
12

18 Exhibit One
19 21-CIV-06653
20
Bank and Escrow Documents
21

21-CIV-06653 Sandadi v. Goswamy
a ay OMB Approval No. 2502-0265
“A
A. FINAL SETTLEMENT STATEMENT (HUD-1) = ™
Lawyers Title Company

B. Type of Loan
{J FHA 2.[_] RHS 3 Conv. Unins | 6. File Number: 7. Loan Number: 8. Mortgage Insurance Case Number:
4. [|VA 5 H Conv. Ins. FLNP-0061500831-LF NCMIX-0094
Cc Note: This form is furnished to give you a statement of actual settlement costs. Amounts paid to and by the Selioment agent are shown.
Items marked "(p.0.c.)" were paid outside the closing; they are shown here for informational purposes and are not included in the totals.
_ ~ (FLNP-0061500831/51)
Name and Address of Buyer: E. Name and Address of Seller: F. Name and Address of Lender:
Surinder P, Goswamy and Satish R. Sandadi M. Kenneth Lavine and Carolyn B. Lavine,
| Northern California Mortgage Fund IX, LLC
152 Nevada Street Trustees of the M. Kenneth Lavine and Carolyn 101 Lucas Valley Rd., Suite 150
Redwood City, CA 94062 B. Lavine 2015 Charitable Remainder Unitrust San Rafael, CA 94903
185 Golden Oak Drive
Portola Valley, CA 94028
Property Location: Settlement Agent: “(650 801 3530) | Settlement Date
1898 Camino A Los Cerros Lawyers Title Company November 6, 2015
Menlo Park, CA 94025 437 Lytton Ave Palo Alto, CA 94301 Disbursement Date:
San Mateo County, California
November 6, 2015
Parcel ID(s): 070-270-120 Place of Settlement
Funding Date
437 Lytton Ave November 5, 2015
Palo Alto, CA 94301
J. Summary of Buyer's Transaction K. Summary of Seller's Transaction
100. Gross Amount Due from Buyer 400. Gross Amount Dr to Seller
101. Contract sales price - 1,525,000.00 401. Contract sales price
102. Personal property 402, Personal property
103. Settlement charges to borrower (line 1400). 39,103.96 403. -
104, - 404
105. 405.
Adjustments for items paid by seller ini advance Adjustments for items paid by seller in advance
106. City/Town taxes 406. City/Town taxes
107. County taxes 11/06/15 to 01/01/16 070-270-120 623.17 407. County taxes to
108. Assessments 408. Assessments
109. 409.
110. - 44
411 _ > 414
112. 412.
120. Gross amount due from Borrower 1,564,727.13 420. Gross amount due to Seller
200. Amounts Paid or Behalf of Buyer 500. Reduction: Amount Due to Seller
201. Deposit or earn money 50,000.00 501 Exces 5 dep (see instructions).
202. Principal amount of new loan(s)_ 1,000,000.00 502. Settlement charges to seller (line 1400)
203. Existir Ken subject to 503. Existing loan(s) taken subject to
204, Buyer fur close > 515,475.00 504. of first mortgage loan_
205. 105. Payoff of second mortgage loan
206. a 506. ca
207 507.
208. 508. ticles
209. 509.
Adjustments for items unpaid by seller Adjustments for items unpaid by seller
210. City/Town taxes B10. City/Town taxes.
211. County taxes 511. County taxes
212. Assessments 512, Assessments.
213. 51
214. 514.
216.
216. 516.
Bie,
218. —— 518.
219. 519.
220. Total paid by/for Borrower 1,565,475,00 520. Total reduction amount due Seller
ce
300. Cash at Settlement from/to Buyer 600. Cash at Settlement from/to Seller
301, Gross amount due from Borrower (Line 120) 1,564,727.13 601, Gross amount du ler (Line 420)
302. Less amount paid by/for Borrower (Line 220) ( 1,565,475.00)| 602, Less reductions due Seller (Line 520)
303. CASH TO BORROWER 747.87 603. CASH TO SELLER
L. Settlement Charges
700, Total Real Estate Broker Fees
so
Paid From Paid From
Division of commission (line 700) as follows Buyer's Seller's
701 to Funds at Funds at
702 to Settlement Settlement
703. Commission pai settlement
704,
ss
800. Items Payable in Connection with Loan
801 (Our f origination charge $5,000.00 ( GFE #1)
802. Your credit or charge (points)
for the specific interest rate chosen (from GFE #2)
. Your adjusted origination charges to Nc ern California M ge Fund IX, LLC from GFE #A) 00
804. Appraisal fee co (from GFE #3)
805. Credit report - (from GFE #3)
806 . Tax service (from GFE #3)
807 Flood certification (from E #3)
808 Document & Processing Fee to FJM Management, LLC < 995.00
809. Mortgag r Commission/Fee ‘JM Capital, Inc 20,000.00
810. ~
811
900. items Required by Lender to be Paid in Advance
—
901 Interest from 11/05/15 to 12/01/15 to Northern California Mortga@ $246.58000/day
(from GFE#10)
902. Mortgage irance premium _ month to (irom GFE #3)
6,410.96}
903 Homeown: insurance year 9, (irom GFE #11)
904. year to ee
905.
1000, Reserves Deposited with Lender a
1001 Initial depos! Our escrow account (from GFE #9)
1002. Homeowner’ rance Montt per Month -
1003. Mortgage insurance Months @ $ per Month
1004. Property taxes Months @ per Month
10085. Flood Insurance Months @ $ per Month a
1006. - Months @ $ nth
1007. Months @ $ per Month
1008 Aggregate Adjustmeni
1100. Title Charges
1101 Tit and lender's title insu
- (from GFE #4) 3,489.00
1102. Set closing fee :980.00
1103. Owner's title insurance to Lawyers Title Company _ (from GFE#5) 3,059.00
a
1104 ender's title insurance $1,324.00 See adait nal 1104 items
1105. Lender's title policy limit $1,250,000.00
1106. Owner's title policy limit $1,525,000.00
co —_—|-—_—
1107. Agent's portion of the total title insurance premium to Lawyers Title Company $3,857.04
1108. Underwriter's portion of the total tite insur im to Commonwealth Cand Tile Insurance G $525.96
1109, Notary Fee to Loren Frediani -
1110. ‘bile Signing Fee/Notary to Nicole Cottonaro $125.
1111 Notary Fee to Bancsery $60.00
1112, ~
1113.
1200. Government Recording and Transfer Charges
1201 Government recordin, 1rgesto San Mateo County Recorder (from GFE #7) 150.00
1202. Deed $ 5 Mortgage $ Releases $
1203, Transfer taxes (from GFE #8)
1204, City/County tax/stamps _ Deed $ Mortgage $
te tax/s' Deed
1206, Aggregate Recording Charges Other $7
4207, ‘San Mateo County Transfer Tax Deed $1,677.
1208.
1300. Additional Settlement Charges
1301 Required s ‘ou can shop for
1302. -
1303.
1304. Property Taxes ~ Ast Installment 20) faxes to San Mateo (
1305. HOA Charges
1301 HOA
1307 HOA Charges
1308 Home
1309. Pest Inspection
8
Comparison of Good Faith Estimate (GFE) and HUD-1 Charges
Charges That Cannot Increase HUD-1 = Line Number Good Faith Est ate HUD-1
Your credit or charge (points) for the specific interest rate chosen # 802 0.00 0.00
Transfer taxes #1203 0.00 0.00
#
Charges That In Total Cannot Increase More Than 10% Good F; timate HUD-1
0.00 0.00
Appraisal fee” 804 0.00 0,00
Credit report 805 0.00 0.00
TaxaK Se
service 806 0.00 0.00
Flood certification 807 0.00 0.00
Total 0.00 0.0
Increase between GFE and HUD-1 Charges 0.00 or 0.00 %
Charges That Can Change h Estimate HUD-1
nn
Initial deposit for your escrow account _ #1001 00 0.00
Homeowner's insurance # 903 0.00 0.00

Loan Terms
i
Your initial loan amount is $ 1,000,000.00
~
Your loan term is NIA
~
Your interest rate is 9.00000%
Your initial monthly amount owed for principal, interest and $ N/A includes
any mortgage insurance is O Principal
LX] Interest
O Mortgage Insurance
~
Can your interest rate rise? Ek] No D1 Yes, it can rise to a maximum of The first %.
change will be and can change again every after
Every change date, your interest rate can increase or decrease by %
Over the life of the loan, your interest rate is guaranteed to never be
lower than _* oror higher than %
Even if you make payments on time, can your loan balance rise? ] No oO Yes, it can rise to a maximum of $
Even if you make payments on time, can your monthly No. Oo Yes the first increase can be and the monthly
amount owed for principal, interest, and mortgage insurance rise? amount owed can rise to $ The maximum it can ever rise to’
- is $
Does your loan havea prepayment Penalty?” EI No Oy Yes, } Your maxinsus prepayment |penalty is$
a ce
Does your loan have a balloon payment? EI No O° Yes, you havea balloon payment of $
due in years on
Total monthly amount owed including escrow account payments [I] You do not have a monthly escrow payment for items, such as
property taxes and homeowners insurance. You must pay these
items directly yourself.
1 You have an additional monthly escrow payment of $ that
results in a total initial monthly amount owed of $.

This includes principal, interest, any mortgage insurance and any
items checked below:
1 Property taxes
(1 Homeowner's insurance
1 Flood insurance
si
Lawyers Title Company
437 Lytton Ave, Palo Alto, CA 94301
Phone: (650)801-3530

FINAL BUYER'S HUD-1, ATTACHMENT
Settlement Date: November 6, 2015 Escrow no.: LT-0006-FLNP-0061500831
Disbursement Date: November 6, 2015 Escrow Officer: Loren Frediani
Settlement Agent: Lawyers Title Company Place of Settlement: 437 Lytton Ave
(650)801-3530 Palo Alto, CA 94301
Buyer : Surinder P. Goswamy Buyer: Satish R. Sandadi
152 Nevada Street 2141 Watermill Road
Redwood City, CA 94062 San Ramon, CA 94582
Seller : M. Kenneth Lavine and Carolyn B. Lender : Northern California Mortgage Fund
Lavine, Trustees of the M. Kenneth IX, LLC
Lavine and Carolyn B. Lavine 2015 101 Lucas Valley Rd., Suite 150
Charitable Remainder Unitrust San Rafael, CA 94903
185 Golden Oak Drive
Portola Valley, CA 94028

Property: 1898 Camino A Los Cerros
Menlo Park, CA 94025
San Mateo County, California
Parcel ID(s): 070-270-120

Title Services
Description Buyer
Line 1102 Detail -
Payee: Lawyers Title Company
Escrow Fee 1,700.00
New Loan Services Fee 280.00
Line 1102 Total 1,980.00
Line 1103 Detail -
Payee: Lawyers Title Company
Owner's title insurance 3,059.00
Line 1103 Total 3,059.00
Line 1104 Detail -
Payee: Lawyers Title Company
Lender's title insurance 1,299.00
ALTA 8.1-06 - Environmental Protection Lien (CLTA 110.9-06) 25.00
Line 1104 Total 1,324.00
Line 1110 Detail -
Payee: Nicole Cottonaro
Mobile Signing Fee/Notary 125.00
Line 1110 Total 125.00
Line 1111 Detail -
Payee: Bancserv
Notary Fee 60.00
Line 1111 Total 60.00
Total Title Services 6,548.00
Go
Lawyers Title Company
437 Lytton Ave, Palo Alto, CA 94301
Phone: (650)801-3530

BUYER'S STATEMENT
Settlement Date November 6, 2015 Escrow Number: LT-0006-FLNP-0061500831
Disbursement Date November 6, 2015 Escrow Officer: Loren Frediani
Buyer: Satish R Sandadi
Buyer: Surender P. Goswamy
Seller: Kenneth Lavine and Carolyn Lavine
1898 Camino A Los Cerros
Menlo Park, CA 94025
Property: 1898 Camino A Los Cerros
Menlo Park, CA 94025
Parcel ID(s): 070-270-120

$ DEBIT $ CREDIT
FINANCIAL CONSIDERATION
Contract sales price 1,525,000.00
Deposit or earnest money Satish R Sandadi < 50,000.00

PRORATIONS/ADJUSTMENTS
ist Installment 2015-2016 11/06/15to 01/01/16 ($2,039.46 / 180 X 55 days) 623.17
Taxes
RE: 070-270-120

TITLE & ESCROW CHARGES
Escrow Fee Lawyers Title Company 1,700.00
Owner's title insurance Lawyers Title Company 3,059.00
Policies to be issued:
Owners Policy
Coverage: $1,525,000.00 Premium: $3,059.00

RECORDING CHARGES
Government recording charges Lawyers Title Company 150.00

Subtotals 1,530,532.17 50,000.00
Balance Due FROM Buyer 1,480,532.17

TOTALS 1,530,532.17, 1,530,532.17
Bank
of America Preferred Rewards
P.O. Box 15284
Wilmington, DE 19850 Customer service information

» 1.888.888.RWDS (1.888.888.7937)
TDD/TTY users only: 1.800.288.4408
SATISH REDDY SANDADI
En Espafiol: 1.800.688.6086
SRINEELA MADADI
606 DROMANA CT bankofamerica.com
SAN RAMON, CA 94582-5670
Bank of America, NA.
P.O. Box 25118
Tampa, FL 33622-5118

Please see the Account Changes section of your statement for details regarding important changes to your account.

Your Adv Tiered Interest Chkg
Preferred Rewards Platinum Honors
for October 29, 2015 to November 25, 2015 Account number: 0018 8060 0038
SATISH REDDY SANDADI SRINEELA MADADI

Account summary
Beginning balance on October 29, 2015 $5731 38.29
aa
Deposits and other additions 10,031.68
ATM and debit card subtractions -2,113.73

Other subtractions -529,154.58
_
Checks 2,690.80
—
Service fees

Ending balance on November 25, 2015 :
2500
$49,185.86

Annual Percentage Yield Earned this statement period: 0.02%.
Interest Paid Year To Date: $52.31.

MERRILL
Read our article online:

“How much do | really need to save for retirement?” oS
rm :
Find out if you're saving enough at merrilledge.com/howmuch
Sone poaton

Merrill Edge" is available through Merill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S), and consists of the Memll Edge Advisory Center” (investment guidance)
and self-directed online investing. MLPF&S is a registered broker-dealer, Member SIPC and a wholly owned subsidiary of Bank of America Corporation. Merrill Lynch,
Merrill Edge, the Merrill Edge logo, and Merrill Edge Advisory Center are trademarks of Bank of America Corporation.
Investment products: Are Not FDIC Insured | Are Not Bank Guaranteed | May Lose Value ARBR5SAK | SSM-08-15-0440.B

bina eveIE: 4B DERE RFIIWEDW TOF IMARES 1 an. ona Daan 4 nfo
SATISH REDDY SANDADI | Account #0018 8060 0038
4
1
October 29,2015 to November 25,2015 _
IMPORTANT INFORMATION:
BANK DEPOSIT ACCOUNTS
Updating your contact information - We encourage you to keep your contact information up-to-date. This includes address, email
and phone number. If your information has changed, the easiest way to update it is by visiting the Help & Support tab of Online
Banking. Or, you can call our Customer Service team.

Deposit agreement - When you opened your account, you received a deposit agreement and fee schedule and agreed that your
account would be governed by the terms of these documents, as we may amend them from time to time. These documents are
part of the contract for your deposit account and govern all transactions relating to your account, including all deposits and
withdrawals. Copies of both the deposit agreement and fee schedule which contain the current version of the terms and
conditions of your account relationship may be obtained at our banking centers.

Electronic transfers: In case of errors or questions about your electronic transfers - If you think your statement or receipt is
wrong or you need more information about an electronic transfer (e.g., ATM transactions, direct deposits or withdrawals,
point-of-sale transactions) on the statement or receipt, telephone or write us at the address and number listed on the front of
this statement as soon as you can. We must hear from you no later than 60 days after we sent you the FIRST statement on
which the error or problem appeared.

Tell us your name and account number.
Describe the error or transfer you are unsure about, and explain as clearly as you can why you believe there is an error or
why you need more information.
Tell us the dollar amount of the suspected error.

For consumer accounts used primarily for personal, family or household purposes, we will investigate your complaint and will
correct any error promptly. If we take more than 10 business days (10 calendar days if you are a Massachusetts customer) (20
business days if you are a new customer, for electronic transfers occurring during the first 30 days after the first deposit is
made to your account) to do this, we will credit your account for the amount you think is in error, so that you will have use of the
money during the time it will take to complete our investigation.

For other accounts, we investigate, and if we find we have made an error, we credit your account at the conclusion of our
investigation.

Reporting other problems - You must examine your statement carefully and promptly. You are in the best position to discover
errors and unauthorized transactions on your account. If you fail to notify us in writing of suspected problems or an
unauthorized transaction within the time period specified in the deposit agreement (which periods are no more than 60 days
after we make the statement available to you and in some cases are 30 days or less), we are not liable to you for, and you agree
to not make a claim against us for the problems or unauthorized transactions.

Direct deposits - If you have arranged to have direct deposits made to your account at least once every 60 days from the same
person or company, you may call us at the telephone number listed on the front of this statement to find out if the deposit was
made as scheduled. You may also review your activity online or visit a banking center for information.

Bank of America, N.A. Member FDIC and e Equal Housing Lender

Pane 2 af0
Your checking account
Bankof America
SATISH REDDY SANDADI | Account # 0018 8060 0038 | October 29, 2015 to November 25, 2015

Deposits and other additions
Date Description Amount
10/29/15 Counter Credit 1,469.00
:
11/1015 Counter Credit 8,310.00
ee _
11/20/15 BANK OF AMERICA DES:CASHREWARD ID: SANDADI INDN 0000000205896553000000 co 250.00
1D:2002290310 PPD

11/25/15 Interest Earned 2.68

Total deposits and other additions $10,031.68

Withdrawals and other subtractions

ATM and debit card subtractions
Date Description Amount
10/29/15 SAFE

Case Info

Judge

Finigan, Jeffrey R. Track Judge’s New Case

Case No.

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Document Filed Date

July 01, 2024

Case Filing Date

December 16, 2021

County

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