Preview
FILED: SCHENECTADY COUNTY CLERK 06/08/2022 04:09 PM INDEX NO. 2022-890
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/08/2022
SUPREME COURT OF THE STATE NEW YORK
Of
COUNTY OF SCHENECTADY
ALBANY MEDICAL CENTER HOSPITAL
1275 BROADWAY
MENANDS, NY 12204
SUMMONS
Plaintiff,
Index No.
Date Filed
ANGELIQUE G GOODWIN
Defendant(s).
TO THE ABOVE NAMED DEFENDANT(S) :
YOU ARE HEREBY SUMMONED to answer the complaint In thisaction and to serve a copy of
your answer on the plaintiff'sattorneys within twenty days after service of this summons, exclusive of the
day of service, or thirtydays after service is completed if this
summons isnot personally delivered to you
within the State of New York. Upon your failure to answer, a Judgment will be entered against you by
default for thereliefdemanded in the complaint.
The basis of venue Isthat the defendant reside(s) in the County of SCHENECTADY.
Dated: 05
Brian S. Stro I,Esq.
OVERTON, USSE GERR AND DONOVAN, LLP
Attorneys for aintiff
19 Executive Park Dr.
CliftonPark, New York 12065
(518) 383-4876
FOR PROCESS SERVER ONLY
DEFENDANT 1: DEFENDANT 2:
ANGELlQUE G GOODWIN
1728 CARRIE ST
SCHENECTADY, NY 12308
NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
1872966-1-Y
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FILED: SCHENECTADY COUNTY CLERK 06/08/2022 04:09 PM INDEX NO. 2022-890
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/08/2022
SUPREME COURT OF THE STATE NEW YORK
Of
COUNTY OF SCHENECTADY
ALBANY MEDICAL CENTER HOSPITAL
VERIFIED
COMPLAINT
Plaintiff,
Index No.
ANGELIQUE G GOODWIN
Defendant(s).
The plaintiffalleges:
1. The PlaintiffIs a domestic corporation authorized to establish and maintain a hospital to render
hospital and medical services.
2. Upon Information and bellef, defendant resides, or the transaction took place in the COUNTY in
which thIs action was commenced and the defendant resides at the address set forth above, such
address being the address of the defendant last known to the plaintiff
and/or the address provided to the
plaintiffby the defendant at the time services were rendered.
3. From December 20, 2017 to February 9, 2018, the at
plaintiff, the express or Implied request of
the defendant, rendered hospital and/or medical services to the defendant, or Individuals for whom the
defendant isfinancially responsible.
4. Upon information and belief, the plaintiff
sent the defendant numerous billingstatements to the
address provided at the time services were rendered or the last known address and before the account
came to counsel's officefor collections. Additionally, counsel's officealso sent written correspondence to
the defendant, at the lastknown address or the address provided tothe and
plaintiff, before commencIng
thIslawsuit. Although due demand has been made, the defendant has failedto pay the fullamount due
for services rendered by the plaintiff.
5. The reasonable value and agreed price of such services that remains unpaid Is$1,584.83.
WHEREFORE , theplaintiffdemands judgment against the defendant in the sum of $1,584.83
with interest from February 9,2018, plus the costs and disbursements of the action and for such other,
further or different relIefas to this Court may deem just.
DATED:
BrIan S. Strohl, .
OVERTON, RUSS , ERR AND DONOVAN, LLP
Attorneys for thePlaintiff
19 Executive Park Dr.
Clifton Park, New York 12065
(518) 383-4876
NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
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FILED: SCHENECTADY COUNTY CLERK 06/08/2022 04:09 PM INDEX NO. 2022-890
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/08/2022
SVC-H-3 (81)
SUPREME COURT OF THE STATE OF NEW YORK :
: as. :
COUNTY OF SCHENECTADY
ALBANY MEDICAL CENTER HOSPITAL
1275 BROADWAY
MENANDS, NY 12204 Plaintiff,
VERIFICATION
ANGELIQUE G GOODWIN Defendant(s).
The undersigned, being duly sworn, deposes and says:
1. I am an officer or agent of the plaintiff,which isa domestic corporation authorized to establish
and malntain a hospital to render hospital and medical services..
2. I have read the foregoing complaint and the same istrue to my knowledge, except those matters
alleged upon information and belief,and as tothose matters, I believe It tobe true.
3. The grounds of my beliefas to allmatters not stated upon my knowledge are the plaintiff's
business records.
KA M
ASS T OF FINANCE
Sworn to befo me this
day of ,20
Notary lic
KEENGRETCHEN WEND
NOTARY PUBLIC, STATE OF NEW YORK
Registration No. 01KB6347057
Qualified in Schenectady County
Commission Expires 2024 1872966-1-Y
September06,
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