Product: Credit card

On XX/XX/XXXX I retained law firm, XXXX XXXX XXXXXXXX XXXX, {$7500.00} ( {$4000.00} paid via XXXX and {$3500.00} paid via Goldman Sachs Bank USA Apple Card ) to represent me in a criminal matter resulting from an incident that occurred on XX/XX/XXXX. XXXX XXXX XXXX informed me and stated in open court that he would file a Motion To Dismiss on my behalf. XXXX XXXX XXXX fired me without cause without filing the Motion To Dismiss and refused to return my retainer. On XX/XX/XXXX I opened a dispute with both XXXX and Apple Card. XXXX immediately resolved the dispute in my favorite same day, but Apple Card has not resolved the dispute after 5 months. 

Below are the full details and supporting communication records. 

1. On or about XX/XX/XXXX, I disputed the {$3500.00} USD charge for services paid to XXXX XXXX XXXXXXXX XXXX, located at XXXX XXXX XXXX XXXX, XXXX, Hawaii XXXX, but not received. 

2. On or about XX/XX/XXXX, Goldman Sachs Bank USA issued me a provisional credit of {$3500.00} USD pending the investigation. 

3. On or about XX/XX/XXXX, Goldman Sachs Bank USA removed the provisional credit of {$3500.00} USD. 

4. On or about XX/XX/XXXX, I called Goldman Sachs Bank USA and asked why the dispute was not resolved in my favor. The representative informed me that my dispute was denied because I did not provide any evidence to support the dispute. I informed the Goldman Sachs representative that I had evidence to support the dispute but I had not been asked to provide it anytime during the investigation. 

5. On or about XX/XX/XXXX, I disputed the {$3500.00} USD charge. 

6. On or about XX/XX/XXXX, Goldman Sachs Bank USA issued me a provisional credit of {$3500.00} USD pending the investigation. 

7. On or about XX/XX/XXXX, I emailed 15 attachments of evidence to support my dispute Goldman Sachs Bank USA at XXXX. 

8. On or about XX/XX/XXXX, I mailed hard copies of 15 attachments of evidence to support my dispute, via USPS certified mail, to Goldman Sachs Bank USA, XXXX XXXX XXXX XXXX, XXXX XXXX, XXXX XXXX XXXX, XXXX, XXXX XXXX. 

9. On or about XX/XX/XXXX, XXXX XXXX XXXX signed for the USPS certified mail wherein 15 hard copies of the evidence to support my dispute. 

10. On or about XX/XX/XXXX, Goldman Sachs Bank USA reversed the provisional credit of {$3500.00}. XXXX USD. 

11. On or about XX/XX/XXXX, I called Goldman Sachs Bank USA and asked why the dispute was not resolved in my favor. The representative informed me that my dispute was denied because I did not provide any evidence to support the dispute. I informed the Goldman Sachs representative that I did provide evidence to support the dispute via email and USPS certified mail. 

12. On or about XX/XX/XXXX, I disputed the {$3500.00} USD charge. 

13. On or about XX/XX/XXXX Goldman Sachs Bank USA issued me, a provisional {$3500.00} USD credit pending the investigation. 

14. On or about XX/XX/XXXX, I called Goldman Sachs Bank USA at XXXX and spoke to Fraud Supervisor Al, who would not give his last name initial or employee number, and informed him that I would not send the evidence in again unless they paid me to because I had already sent it in once via email and once via USPS certified mail. I also informed him that if the dispute were not resolved by the {$3500.00} USD disputed charge being reversed and {$3500.00} in available credit restored to my account by the end of the week I would file a complaint with the Consumer Financial Protection Bureau. 

15. On or about XX/XX/XXXX, I opened a complaint with the Consumer Financial Protection Bureau and submitted evidence to support the complaint, dispute, and demand for resolution. 

16. On or about XX/XX/XXXX at approximately XXXXXXXX XXXX, I received an email from Apple Card Support at, XXXX, informing me that my Apple Card account had been closed as of XX/XX/XXXX. The reason given was : There was a failure to comply with the terms of the Customer Agreement. I have never missed a payment or been late on a payment since opening the account. 

17. On or about XX/XX/XXXX at approximately XXXX XXXX I called Goldman Sachs Bank USA at XXXX and asked Goldman Sachs Bank USA representative, XXXX XXXX why my account had been closed. spoke with XXXX XXXX, who informed me she did not have any other available information beyond what was stated in the email, There was a failure to comply with the terms of the Customer Agreement, as the reason the account was closed. 

18. On or about XX/XX/XXXX, I informed Goldman Sachs Bank USA representative, XXXX XXXX, that I the closure of my account without a substantiated reason would be dealt with as retaliatory. 

19. On or about XX/XX/XXXX, Goldman Sachs Bank USA representative, XXXX XXXX, informed me that she noted that I called asking for information and that she was unable to provide me with the requested information, and that she opened a complaint on my behalf with Apple Card internally, noting that I asked that the dispute be resolved, my account be reinstated, and {$3500.00} USD in available credit be restored to my account. 

20. On or about XX/XX/XXXX, I filed a complaint with the Consumer Financial Protection against Bureau Goldman Sachs Bank USA and provided all supporting evidence including the video and all email communications. 



Below is a full breakdown and all communication between myself and XXXX XXXX  XXXX XXXX which serves as evidence of fraud and supports my dispute of {$3500.00} USD charge paid to XXXX XXXX  XXXX XXXX for services but not received and charged to my Goldman Sachs Bank USA Apple Card. 

1. On Wednesday, XX/XX/XXXX at approximately XXXXXXXX XXXX I called the law firm of XXXXXXXX XXXX XXXXXXXX, XXXX located at XXXX XXXX XXXX XXXX, XXXX, HI XXXX and spoke to XXXX XXXX at the front desk regarding legal representation for an upcoming pre-trial conference on XX/XX/XXXX at XXXX for a criminal matter resulting from an incident that occurred on XX/XX/XXXX. XXXX XXXX informed me that a paralegal would call me to discuss the matter. 

2. On Wednesday, XX/XX/XXXX at approximately XXXXXXXX XXXX  I received a phone call from XXXX XXXX, a paralegal at XXXXXXXX XXXX  XXXX XXXX, who after hearing the circumstances of the matter informed me that the matter was in XXXXXXXX XXXX wheelhouse and a retainer of {$7500.00} USD would be required for him to represent me. I agreed to meet for a consultation and she scheduled my consultation with XXXX XXXX, XXXX. for XX/XX/XXXX at XXXXXXXX XXXX 

3. On Wednesday, XX/XX/XXXX at approximately XXXXXXXX XXXX I received an email from XXXX XXXX with 2 attachments ; a FEE AGREEMENT and a CRIMINAL INTAKE form. 

4. On Monday, XX/XX/XXXX at approximately XXXXXXXX XXXX I met with XXXX XXXX, XXXX. at XXXX XXXX XXXX XXXX, XXXX, XXXX XXXX. I explained the matter and provided XXXX XXXX, XXXX. a copy of my notarized AFFIDAVIT OF TRUTH dated XX/XX/XXXX, regarding the details of the XX/XX/XXXX incident, along with my video evidence of the incident. 

5. On Monday, XX/XX/XXXX at approximately XXXXXXXX XXXX XXXX XXXX, XXXX. agreed to take my case and represent me in the criminal matter with an initial retainer of {$7500.00} USD. I informed XXXX XXXX, XXXX. that I could pay {$4000.00} USD at that time and the balance of {$3500.00} USD the following day. XXXX XXXX, XXXX. agreed. 

6. On Monday, XX/XX/XXXX at approximately XXXXXXXX XXXX  I paid XXXX XXXX XXXX XXXX {$4000.00} USD via my XXXX XXXX credit card ending in XXXX, Transaction # XXXX and signed the FEE AGREEMENT. 

7. On Monday, XX/XX/XXXX at approximately XXXXXXXX XXXX I received an email receipt for payment XXXX in the amount of {$4000.00} USD from XXXX XXXX who works the front desk at XXXX XXXX XXXX XXXX XXXX 

8. On Monday, XX/XX/XXXX at approximately XXXXXXXX XXXX XXXX XXXX, XXXX. assigned XXXX XXXX as my paralegal and instructed her to prepare a MOTION TO DISMISS based on the fact that video evidence showed I acted in self defense. 

9. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX I arrived at XXXX XXXX XXXX XXXX, XXXX, HI XXXX and paid XXXX XXXX XXXX XXXX and paid {$3500.00} USD, the balance of the FEE AGREEMENT, via my XXXX ending in XXXX, Transaction # XXXX, and received a hard copy receipt for payment XXXX in the amount of {$3500.00} USD from the front desk clerk. 

10. On Friday, XX/XX/XXXX at approximately XXXXXXXX XXXX I received an email receipt from XXXX XXXX XXXXXXXX XXXX for the paid invoice # XXXX for {$1000.00} USD. 

11. On Monday, XX/XX/XXXX at approximately XXXXXXXX XXXX I arrived at the XXXX XXXX XXXX in XXXX XXXX XXXX for my pre-trial conference with XXXX XXXX, XXXX. XXXX XXXX, XXXX. informed the judge that we would be filing a Motion To Dismiss and asked the judge to schedule a hearing for the Motion To Dismiss. The judge said the hearing date would be set after the Motion To Dismiss was filed. 

12. On Monday, XX/XX/XXXX at approximately XXXXXXXX XXXX I called the office of XXXX XXXX XXXXXXXX XXXX and spoke with XXXX XXXX regarding the timeline for the motion to dismiss. She informed me that the week beginning XX/XX/XXXX was a light work load week for her and she would have the Motion To Dismiss prepared for XXXX XXXX, XXXX. to review on Wednesday, XX/XX/XXXX, and have it ready for my review Thursday, XX/XX/XXXX XXXX, and have it filed on Friday, XX/XX/XXXX. XXXX XXXX told me she would email me a XXXX link for me to upload my video recording of the incident that occurred on XX/XX/XXXX for her as XXXX XXXX XXXX. had not provided her with it. 

13. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX  I emailed XXXX XXXX stating : " I haven't received the XXXX link from you yet. Please advise. '' 14. On Tuesday, XX/XX/XXXX at approximately XXXX XXXX  I received an email from XXXX XXXX stating : " let me know if this works '' along with a XXXX link. 

15. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX  I emailed XXXX XXXX stating : " I uploaded the video. '' 16. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX  I received an email from XXXX XXXX stating : " got it thanks ''. 

17. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX I emailed XXXX XXXX stating : " Ok ''. 

18. On Wednesday XX/XX/XXXX at approximately XXXX XXXX I emailed XXXX XXXX asking : Are we on schedule for the Motion To Dismiss to be filed by Friday? 

19. On Wednesday XX/XX/XXXX at approximately XXXX XXXX on Wednesday XX/XX/XXXX she replied via email : Yes we are. 

20. On Thursday, XX/XX/XXXX at approximately XXXXXXXX XXXX I emailed XXXX XXXX asking : When will the draft be ready for my review? '' I did not receive a response. 

21. On Thursday, XX/XX/XXXX at approximately XXXXXXXX XXXX  I received an email receipt from XXXX XXXX XXXXXXXX XXXX for the paid invoice # XXXX for {$570.00} USD. 

22. On Friday, XX/XX/XXXX at approximately XXXX XXXX I emailed XXXX XXXX the stating : Please advise. I did not receive a response. 

23. On Friday, XX/XX/XXXX at approximately XXXX XXXX I called XXXX XXXX  XXXX XXXX and spoke with XXXX XXXX. She informed me that something came up and XXXX XXXX, XXXX. had not yet reviewed the Motion To Dismiss and that it would be ready for my review Monday, XX/XX/XXXX. 

24. On Tuesday, XX/XX/XXXX at approximately XXXX XXXX I emailed XXXX XXXX asking : Do you have an update? 

25. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX  I received an email from XXXX XXXX stating : yes, XXXX is going to review today. Yesterday he was in court almost all day and trial prep. Once he reviews will send to XXXX to review then will have draft for by the end of the day. 

26. On Tuesday, XX/XX/XXXX at approximatXXXX XXXX XXXX I emailed XXXX XXXX asking : Does the motion to dismiss address each of the following : -Reasonable force, -Imminent threat, -Duty to retreat. Please advise. 

27. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX I received an email from XXXX XXXX stating : Sorry for the delay, the motion does address the first two, with regard to the duty to retreat- i read the statue regarding this and i will double check with XXXX, but I believe this would hurt not help. Again, let me discuss with XXXX and will let you know. 

28. On Tuesday, XX/XX/XXXX at approximately XXXXXXXX XXXX I emailed XXXX XXXX stating : Ok, thanks. 

29. On Tuesday, XX/XX/XXXX at approximately XXXX XXXX I emailed XXXX XXXX stating : Give me a call when you have a few minutes. 

30. On Wednesday, XX/XX/XXXX at approximately XXXX XXXX I called XXXX XXXX XXXXXXXX XXXX asking to speak with XXXX XXXX. The person who answered the phone told me she wasn't available and to leave her a voicemail. I left XXXX XXXX a voicemail asking her to call me back. 

XXXX. On Wednesday, XX/XX/XXXX at approximately XXXX XXXX I emailed XXXX XXXX stating : I would like a call back. 

32. On Thursday, XX/XX/XXXX at approximately XXXXXXXX XXXX I called XXXXXXXX XXXX XXXX XXXX and asked to speak to XXXX XXXX. The person who answered the phone told me she wasn't available and to leave her a voicemail. I left XXXX XXXX a voicemail asking her to call me back. 

33. On Thursday, XX/XX/XXXX at approximately XXXX XXXX I received an email from XXXX XXXX stating : I realize you have left messages for me, and Im sorry I havent been able to get back to you. XXXX has me focused on preparing for his trial that starts Monday, and that has to be my priority for the moment. I apologize, but that is the nature of this job. I will be giving you the same focus and priority as soon as I can, but when my supervising attorney tells me to do something, thats what I do. I know that when we first started on your case I had mentioned to you that I we had some other trials going up, so I hope you can understand. You will have our focus very soon. In the meantime, if you need to give us any information, emails are the best way. 

34. On Thursday, XX/XX/XXXX at approximately XXXX XXXX I called XXXX XXXX  XXXX XXXX and asked to speak with XXXX XXXX, XXXX. The person who answered the phone told me that he was busy in a consultation for the next hour. I explained my frustration with the lack of communication and lack of progress to the person on the phone. She told me she understood my concern and informed me that she was just the bookkeeper. I told her that I would be at their offices within the hour, at XXXX XXXX and available to speak with XXXX XXXX, XXXX. if he was available after his consultation. 

35. On Thursday, XX/XX/XXXX at approximately XXXX XXXX I arrived XXXX XXXX XXXX XXXX, XXXX, HI XXXX and waited in my car in the parking lot. 

36. On Thursday, XX/XX/XXXX at approximately XXXX XXXX I received a call from XXXX XXXX XXXXXXXX XXXX asking if I was in the parking lot. I stated, Yes. The woman who called me stated that XXXX XXXX, XXXX. would be available to speak to me in a few minutes.

37. On Thursday, XX/XX/XXXX at approximately XXXX XXXX I arrived inside the offices of XXXX XXXX  XXXX XXXX and was told to wait in the consultation room. XXXX XXXX, XXXX. arrived a few minutes later and asked, What is going on?

38. On Thursday, XX/XX/XXXX at approximately XXXXXXXX XXXX I told XXXX XXXX, XXXX. that, This was not working. XXXX XXXX, XXXX. replied, Then fire me. I said, I do not want to fire you, I want the Motion To Dismiss filed. I said, XXXX XXXX told me it would be ready for my review a week ago and I still havent received anything from her. XXXX XXXX, XXXX. said, Well, if you dont want to fire me I will fire you! as he got up and stormed out of the consultation room. I said, If you want to be done with me then you need to give me my money back because you havent done what you said you would do. XXXX XXXX, XXXX. said, That is not going to happen! As he went into his office and slammed the door. 

39. On Thursday, XX/XX/XXXX at approximately XXXX XXXX I walked to the reception area and told the bookkeeper, XXXX XXXX who was sitting at the front desk, I have no idea what just happened in there, shaking my head as I sat down. XXXX XXXX asked me if I wanted to terminate the contract, I said, No, that is not what I want to do. What I need is my Motion To Dismiss filed. The bookkeeper, XXXX XXXX, called XXXX XXXX and asked her come up to the reception area to talk to me. 

40. On Thursday, XX/XX/XXXX at approximately XXXXXXXX XXXX XXXX XXXX arrived in the reception area and said, I am so sorry, this is my fault. I didnt get back to you, I have just been so busy preparing for the trial next week. I said, I just want the Motion To Dismiss filed so I can move forward. I would like to see the draft you have prepared so far. XXXX XXXX said, Its not really presentable right now. I said, Thats fine, just give me whatever you have. XXXX XXXX said, Its just a jumbled up mess right now and it wouldnt make any sense. Let me talk to XXXX and let him know it was my fault and see if we can go ahead and get the motion filed for you. I said, Ok, when will you let me know what he says? XXXX XXXX said, I will let you know around noon tomorrow. The bookkeeper, XXXX XXXX, who was sitting at the front desk asked her if she wanted her to set a reminder for her. XXXX XXXX said, Yes, set it for XXXX. 

41. On Friday, XX/XX/XXXX at approximately XXXX XXXX XXXX XXXX emailed me stating : XXXX XXXX, I wanted to reach out as I stated yesterday, I would talk to XXXX regarding everything and let you know what he says. I have not had the chance to talk with him, I am hoping to get a small break from trial prep for both us so I can talk to him. If not today, I will email him with what the breakdown was and also follow up Monday morning before court. I wanted to make sure I let you know I have not been able to talk as I had hoped yesterday. 

42. On Friday, XX/XX/XXXX at approximately XXXX XXXX I replied via email : Ok. Thank you for the update. 

43. On Wednesday, XX/XX/XXXX at approximately XXXXXXXX XXXX I emailed XXXX XXXX asking : Do you have an update? I did not receive a response. 

44. On Thursday, XX/XX/XXXX at approximately XXXX XXXX I emailed XXXX XXXX asking : Do you have an update? I did not receive a response. 

45. On Tuesday, XX/XX/XXXX at approximately XXXX XXXX I emailed XXXX XXXX asking : Do you have an update? I did not receive a response. 

46. On Thursday, XX/XX/XXXX at approximately XXXX XXXX XXXX XXXX responded via email stating : XXXX XXXX, Yes, after discussions with both XXXX and XXXX, it has been decided that unfortunately we can no longer represent you. I will be preparing the motion to withdraw and have filed by tomorrow. I will make sure to email you a copy of the motion as well as time and date of the hearing. 

The facts provided herein collectively prove and or demonstrate fraudulent behavior by XXXX XXXX XXXXXXXX XXXX. 

Misrepresentation of Services : XXXX XXXX  XXXX XXXX represented that they would provide legal representation in the criminal matter resulting from the incident that occurred on XX/XX/XXXX, but failed to fulfill this commitment. By promising to prepare and file the Motion To Dismiss, discussing the matter with XXXX XXXX, scheduling a consultation, and sending me a fee agreement and criminal intake form, they created an expectation that legal services would be provided. 

False Representation of Work : XXXX XXXX informed me that the Motion To Dismiss would be prepared and ready for XXXX XXXX XXXX. to review by a specific date but repeatedly failed to provide a draft or any substantial progress. This false representation of work and ability to meet deadlines is considered fraudulent. 

Non-performance and Delay Tactics : XXXXXXXX XXXX  XXXX XXXX consistently failed to follow through on their obligations, including failing to file the Motion To Dismiss and repeatedly delaying the provision of necessary documents. Their repeated promises and subsequent delays is fraudulent behavior. 

Failure to Communicate and Provide Updates : XXXXXXXX XXXX XXXX XXXX failed to respond to my emails seeking updates and information, leaving me in the dark about the progress of my case. This lack of communication raises concerns about transparency and professionalism. 

Unjust Enrichment : XXXX XXXX XXXXXXXX XXXX collected a substantial retainer fee of {$7500.00} USD from me but failed to provide the agreed-upon legal services. Their retention of the fee without fulfilling their promises is unjust enrichment.