On April 21, 2022 a
Party Statement
was filed
involving a dispute between
Bayfront Health Port Charlotte,
Port Charlotte Hma Llc,
and
Johnson, William J,
in the District Court of Sarasota County.
Preview
Filing # 132284127 E-Filed 08/09/2021 01:27:29 PM
IN THE COUNTY COURT, IN
THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
CASE NO: 21001566SP
PORT CHARLOTTE HMA LLC DBA BAYFRONT HEALTH PORT
CHARLOTTE
Plaintiff(s),
-vs-
WILLIAM J JOHNSON
Defendant(s).
/
COMPLAINT
Plaintiff(s), PORT CHARLOTTE HMA LLC DBA BAYFRONT HEALTH PORT
CHARLOTTE sue(s) Defendant, William J Johnson, and allege(s):
l. This is an action for damages sounding of quantum meruit, which are $5,296.90,
exclusive of interest, costs, and fees by virtue of which this Court has jurisdiction.
2. Defendant is a resident of Charlotte County, Florida and/or the subject matter
hereof was transacted in Charlotte County, Florida.
3. On one or more dates, with the last date being November 21, 2019, Plaintiff
rendered medical treatment for Defendant and/or Defendant's lawful dependent.
4. Defendant had knowledge of, and/or acquiesced in, the rendering of the medical
services by Plaintiff.
5. Defendant was aware that Plaintiff expected to be compensated for the medical
services rendered by Plaintiff.
6. Defendant has been unjustly enriched by receiving the medical services rendered
by Plaintiff and it would be inequitable for Defendant to retain the benefit of such medical services
without paying fair value for the same.
7. Defendant failed to pay on demand.
8. Plaintiff would welcome settlement either by lump sum or monthly payment
arrangements by contacting the law firm at 866-603-8129. Defendant must still comply with all of
the Court’s requirements.
WHEREFORE, Plaintiff prays this Honorable Court to enter a Judgment against
Defendant, in favor of the Plaintiff, for the principal amount plus court costs.
In compliance with Federal Law you are advised that this is an attempt to collect a debt
and any information obtained will be used for that purpose.
DATED at Cocoa, Brevard County, Florida, August 6, 2021.
LOTANE & ASSOCIATES, P.A.
Filed 04/21/2022 09:42 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLAttorneys At Law
/s_Troy R. Lotane
TROY R. LOTANE
Florida Bar No: 163015
ADEKEMI AKINWOLE
Florida Bar No: 124018
CHRISTOPHER BIDDULPH
Florida Bar No: 118094
EDWARD BUTLER
Florida Bar No: 118113
SARAH JORDAN
Florida Bar No: 93558
ANTHONY STEELE
Florida Bar No: 74810
Rule 2.515 Designated Service Email:
Service@ Lotane.com
1980 Michigan Avenue
Cocoa, Florida 32922
(321) 636-4861 / (800) 807-3334
Attorneys for Plaintiff(s)
L |
*Q417860MCTI2-*
Document Filed Date
April 21, 2022
Case Filing Date
April 21, 2022
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 132284127 E-Filed 08/09/2021 01:27:29 PM IN THE COUNTY COURT, IN THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION CASE NO: 21001566SP PORT CHARLOTTE HMA LLC DBA BAYFRONT HEALTH PORT CHARLOTTE Plaintiff(s), -vs- WILLIAM J JOHNSON Defendant(s). / COMPLAINT Plaintiff(s), PORT CHARLOTTE HMA LLC DBA BAYFRONT HEALTH PORT CHARLOTTE sue(s) Defendant, William J Johnson, and allege(s): l. This is an action for damages sounding of quantum meruit, which are $5,296.90, exclusive of interest, costs, and fees by virtue of which this Court has jurisdiction. 2. Defendant is a resident of Charlotte County, Florida and/or the subject matter hereof was transacted in Charlotte County, Florida. 3. On one or more dates, with the last date being November 21, 2019, Plaintiff rendered medical treatment for Defendant and/or Defendant's lawful dependent. 4. Defendant had knowledge of, and/or acquiesced in, the rendering of the medical services by Plaintiff. 5. Defendant was aware that Plaintiff expected to be compensated for the medical services rendered by Plaintiff. 6. Defendant has been unjustly enriched by receiving the medical services rendered by Plaintiff and it would be inequitable for Defendant to retain the benefit of such medical services without paying fair value for the same. 7. Defendant failed to pay on demand. 8. Plaintiff would welcome settlement either by lump sum or monthly payment arrangements by contacting the law firm at 866-603-8129. Defendant must still comply with all of the Court’s requirements. WHEREFORE, Plaintiff prays this Honorable Court to enter a Judgment against Defendant, in favor of the Plaintiff, for the principal amount plus court costs. In compliance with Federal Law you are advised that this is an attempt to collect a debt and any information obtained will be used for that purpose. DATED at Cocoa, Brevard County, Florida, August 6, 2021. LOTANE & ASSOCIATES, P.A. Filed 04/21/2022 09:42 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLAttorneys At Law /s_Troy R. Lotane TROY R. LOTANE Florida Bar No: 163015 ADEKEMI AKINWOLE Florida Bar No: 124018 CHRISTOPHER BIDDULPH Florida Bar No: 118094 EDWARD BUTLER Florida Bar No: 118113 SARAH JORDAN Florida Bar No: 93558 ANTHONY STEELE Florida Bar No: 74810 Rule 2.515 Designated Service Email: Service@ Lotane.com 1980 Michigan Avenue Cocoa, Florida 32922 (321) 636-4861 / (800) 807-3334 Attorneys for Plaintiff(s) L | *Q417860MCTI2-*