On October 18, 2019 a
Complaint,Petition
was filed
involving a dispute between
North Broward Hospital District,
and
Cardenas, Olga,
for 3
in the District Court of Broward County.
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Case Number: CACE-19-021561 Division: 08
Filing # 97513448 E-Filed 10/18/2019 12:34:12 PM
IN THE CIRCUIT COURT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.
ATTORNEY BAR NO. 94234
NORTH BROWARD HOSPITAL DISTRICT
Plaintiff,
vs COMPLAINT FOR DAMAGES
OLGA CARDENAS
Defendant.
COMES NOW, the Plaintiff, by and through its undersigned
attorneys and sues the Defendant(s) and states as follows:
General Allegations
1. This is an action for damages that are within
the court's jurisdictional limit.
2. That the patient received services in this County
and that payment is due from the Defendant(s) in this County.
COUNT I - Quantum Meruit
That the Defendant was a patient at Plaintiff's facility
on the dates as set forth in Exhibit waAN not attached hereto.
Exhibit "A" is not included as an attachment to the Complaint,
because including same would require Plaintiff to violate
Federal HIPAA rules involving patient privacy. A copy of the
Complaint with Exhibit "A" will be provided to Defendant (s)
when an appearance is entered in the lawsuit or a request is
made upon Plaintiff for same.
That during the medical admission, the patient received the
benefit of medical services and supplies. The Defendant was
billed the reasonable value of said medical services and
supplies, and there presently remains due and owing the
Plaintiff the sum as set forth below, plus interest since
the date of discharge.
That demand for payment has been made by Plaintiff and
the Defendant has refused to make full payment.
WHEREFORE, Plaintiff demands judgment against the Defendant(s).
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/18/2019 12:34:10 PM.**#*
COUNT II - Account Stated
Plaintiff realleges paragraphs 1 and 2 above and further states that:
6. Before the institution of this action Plaintiff and
Defendant(s), had business transactions between them and
they agreed to the resulting balance.
Plaintiff rendered a statement of it to Defendant(s),
a copy not being attached hereto and marked Exhibit "A", and
the Defendant(s), did not object to the statement.
Exhibit "A" is not included as an attachment to the Complaint,
because including same would require Plaintiff to violate
Federal HIPAA rules involving patient privacy. A copy of the
Complaint with Exhibit "A" will be provided to Defendant (s)
when an appearance is entered in the lawsuit or a request is
made upon Plaintiff for same.
8. Defendant(s), owes Plaintiff the sum set forth below that
is due with interest since the date of discharge.
WHEREFORE, Plaintiff demands judgment in its favor and
against the Defendant(s).
COUNT III - Open Account
Plaintiff realleges paragraphs 1 and 2 above and further states that:
9 Defendant(s), owes Plaintiff the sum set forth below, that
is due with interest since the date of discharge according
to the statement of account not attached hereto and marked
Exhibit waAN Exhibit man is not included as an attachment
to the Complaint, because including same would require
Plaintiff to violate Federal HIPAA rules involving patient
privacy. A copy of the Complaint with Exhibit "A" will be
provided to Defendant(s) when an appearance is entered in
the lawsuit or a request is made upon Plaintiff for same.
WHEREFORE, Plaintiff demands judgment in its favor and against
Defendant
(s) .
COUNT IV - Guarantee
Plaintiff realleges paragraphs 1 and 2 above and further states that:
10. Defendant
(s) , for and in consideration of the services
rendered, executed a guarantee of payment marked
Plaintiff's Exhibit wRr, Exhibit "B" is not included
as an attachment to the Complaint, because including same
would require Plaintiff to violate Federal HIPAA rules
involving patient privacy. A copy of the Complaint with
Exhibit "B" will be provided to Defendant(s) when an
appearance is entered in the lawsuit or a request is
made upon Plaintiff for same.
11 That Plaintiff has complied with all conditions precedent
to recover on said guarantee and that Defendant(s) has/have
failed and refused to make full payment thereon.
WHEREFORE, Plaintiff demands judgment in its favor and against
Defendant(s), in the principle sum of $ 26,335.00 together
with interest, court costs, reasonable attorneys' fees, and any
other relief which this court may deem just and proper.
SAGE LAW OFFICES
Attorneys for Plaintiff
1300 Sawgrass Corporate Parkway
Suite 140
Sunrise, Florida 33323
(954) 835-0702
Email: E ey@sagelaw.com
‘ ee
BY:
EDWARD M. HARVEY, ESQ.
This is an attempt to collect a debt and any information obtained will
be used for that purpose. This communication is from a debt collector.
002002662
Ccé
Document Filed Date
October 18, 2019
Case Filing Date
October 18, 2019
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Case Number: CACE-19-021561 Division: 08 Filing # 97513448 E-Filed 10/18/2019 12:34:12 PM IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. ATTORNEY BAR NO. 94234 NORTH BROWARD HOSPITAL DISTRICT Plaintiff, vs COMPLAINT FOR DAMAGES OLGA CARDENAS Defendant. COMES NOW, the Plaintiff, by and through its undersigned attorneys and sues the Defendant(s) and states as follows: General Allegations 1. This is an action for damages that are within the court's jurisdictional limit. 2. That the patient received services in this County and that payment is due from the Defendant(s) in this County. COUNT I - Quantum Meruit That the Defendant was a patient at Plaintiff's facility on the dates as set forth in Exhibit waAN not attached hereto. Exhibit "A" is not included as an attachment to the Complaint, because including same would require Plaintiff to violate Federal HIPAA rules involving patient privacy. A copy of the Complaint with Exhibit "A" will be provided to Defendant (s) when an appearance is entered in the lawsuit or a request is made upon Plaintiff for same. That during the medical admission, the patient received the benefit of medical services and supplies. The Defendant was billed the reasonable value of said medical services and supplies, and there presently remains due and owing the Plaintiff the sum as set forth below, plus interest since the date of discharge. That demand for payment has been made by Plaintiff and the Defendant has refused to make full payment. WHEREFORE, Plaintiff demands judgment against the Defendant(s). #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/18/2019 12:34:10 PM.**#* COUNT II - Account Stated Plaintiff realleges paragraphs 1 and 2 above and further states that: 6. Before the institution of this action Plaintiff and Defendant(s), had business transactions between them and they agreed to the resulting balance. Plaintiff rendered a statement of it to Defendant(s), a copy not being attached hereto and marked Exhibit "A", and the Defendant(s), did not object to the statement. Exhibit "A" is not included as an attachment to the Complaint, because including same would require Plaintiff to violate Federal HIPAA rules involving patient privacy. A copy of the Complaint with Exhibit "A" will be provided to Defendant (s) when an appearance is entered in the lawsuit or a request is made upon Plaintiff for same. 8. Defendant(s), owes Plaintiff the sum set forth below that is due with interest since the date of discharge. WHEREFORE, Plaintiff demands judgment in its favor and against the Defendant(s). COUNT III - Open Account Plaintiff realleges paragraphs 1 and 2 above and further states that: 9 Defendant(s), owes Plaintiff the sum set forth below, that is due with interest since the date of discharge according to the statement of account not attached hereto and marked Exhibit waAN Exhibit man is not included as an attachment to the Complaint, because including same would require Plaintiff to violate Federal HIPAA rules involving patient privacy. A copy of the Complaint with Exhibit "A" will be provided to Defendant(s) when an appearance is entered in the lawsuit or a request is made upon Plaintiff for same. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant (s) . COUNT IV - Guarantee Plaintiff realleges paragraphs 1 and 2 above and further states that: 10. Defendant (s) , for and in consideration of the services rendered, executed a guarantee of payment marked Plaintiff's Exhibit wRr, Exhibit "B" is not included as an attachment to the Complaint, because including same would require Plaintiff to violate Federal HIPAA rules involving patient privacy. A copy of the Complaint with Exhibit "B" will be provided to Defendant(s) when an appearance is entered in the lawsuit or a request is made upon Plaintiff for same. 11 That Plaintiff has complied with all conditions precedent to recover on said guarantee and that Defendant(s) has/have failed and refused to make full payment thereon. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant(s), in the principle sum of $ 26,335.00 together with interest, court costs, reasonable attorneys' fees, and any other relief which this court may deem just and proper. SAGE LAW OFFICES Attorneys for Plaintiff 1300 Sawgrass Corporate Parkway Suite 140 Sunrise, Florida 33323 (954) 835-0702 Email: E ey@sagelaw.com ‘ ee BY: EDWARD M. HARVEY, ESQ. This is an attempt to collect a debt and any information obtained will be used for that purpose. This communication is from a debt collector. 002002662 Ccé