Robo-Signed Affidavit Sufficient to Establish Liability

Defendant denied the amount he owed to American Express. American Express submitted an affidavit of the Custodian of Records to establish the amount due. The court decided that although the affidavit looked “robo-signed, ” it was sufficient to establish that something was owed, but insufficient to establish the amount, especially because the records relied on were only copies of part of the file.