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  • Community Care Physicians, P.C. v. Thomas E QuinnOther Matters - Contract - Other document preview
  • Community Care Physicians, P.C. v. Thomas E QuinnOther Matters - Contract - Other document preview
  • Community Care Physicians, P.C. v. Thomas E QuinnOther Matters - Contract - Other document preview
  • Community Care Physicians, P.C. v. Thomas E QuinnOther Matters - Contract - Other document preview
  • Community Care Physicians, P.C. v. Thomas E QuinnOther Matters - Contract - Other document preview
  • Community Care Physicians, P.C. v. Thomas E QuinnOther Matters - Contract - Other document preview
						
                                

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FILED: RENSSELAER COUNTY CLERK 02/09/2024 11:49 AM INDEX NO. EF2024-276068 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/09/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RENSSELAER COMMUNITY CARE PHYSICIANS, P.C. 711 TROY SCHENECTDY RD LATHAM, NY 12110 SUMMONS Plaintiff, Index No. Date Filed THOMAS E QUINN Defendant(s). TO THE ABOVE NAMED DEFENDANT(S) : YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on the plaintiff s attorneys within twenty days after service of this summons, exclusive of the day of service, or thirty days after service is completed if this summons is not 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 the relief demanded in the complaint. The basis of venue is that the defendant reside(s) in the County of RENSSELAER. Dated: C.C e m ·e / ÊD3 Melissa M. Tobrocke, Esq. ORDD LAW, LLP Attorneys for the Plaintiff 19 Executive Park Dr. Clifton Park, New York 12065 (518) 383-4876 FOR PROCESS SERVER ONLY DEFENDANT 1: DEFENDANT 2: THOMAS E QUINN 523 W SAND LAKE RD WYNANTSKILL, NY 12198 NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4530481/916577090 1 of 3 FILED: RENSSELAER COUNTY CLERK 02/09/2024 11:49 AM INDEX NO. EF2024-276068 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/09/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RENSSELAER COMMUNITY CARE PHYSICIANS, P.C. VERIFIED COMPLAINT Plaintiff, Index No. THOMAS E QUINN Defendant(s). The plaintiff alleges: 1. The Plaintiff is a domestic corporation authorized to establish and maintain a medical practice to render medical and physician services. 2. Plaintiff is licensed under Article 28 of New York State Public Health law or under Title 8 of New York State Education law. 3. Upon information and belief, 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 plaintiff by the defendant at the time services were rendered. 4. From February 10, 2021 to January 9, 2023, the plaintiff, at the express or implied request of the defendant, rendered medical services to the defendant, or individuals for whom the defendant is financially responsible. 5. Upon information and belief, the plaintiff sent the defendant numerous billing statements to the address provided at the time services were rendered or the last known address and before the account came to counsers office for collections. Additionally, counsel's office also sent written correspondence to the defendant, at the last known or the address provided address to the plaintiff, and before commencing this lawsuit. Although due demand has been made, the defendant has failed to pay the full amount due for services rendered by the plaintiff. 6. The reasonable value and agreed price of such services that remains unpaid is $1,054.28. WHEREFORE , the plaintiff demands judgment against the defendant in the sum of $1,054.28 with interest from January 9, 2023, plus the costs and disbursements of the action and for such other, further or different relief as to this Court may deem just. DATED: C C c. /- Melissa M. Tobrocke, Esq. ORDD LAW, LLP Attorneys for the Plaintiff 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. 2 of 3 FILED: RENSSELAER COUNTY CLERK 02/09/2024 11:49 AM INDEX NO. EF2024-276068 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/09/2024 SVC-H-3 (81) SUPREME COURT OF THE STATE OF NEW YORK : : ss. : COUNTY OF RENSSELAER COMMUNITY CARE PHYSICIANS, P.C. 711 TROY SCHENECTDY RD LATHAM, NY 12110 Plaintiff, VERIFICATION THOMAS E QUINN Defendant(s). The undersigned, being duly sworn, deposes and says: 1. I am an officer or agent of the plaintiff, which is a domestic corporation authorized to establish and maintain a medical practice to render medical and physician services. 2. Plaintiff is licensed under Article 28 of New York State Public Health law or under Title 8 of New York State Education law. 3. I have read the foregoing complaint and the same is true to my knowledge, except those matters alleged upon information and belief, and as to those matters, I believe it to be true. 4. The grounds of my belief as to all matters not stated upon my knowledge are the plaintiff s business records. TERRI BOOMHOWER PATIENT RELATIONS MANAGER Sworn to before me this day of ,20 Mary Jo Teresco Notary Public State of New York Qualified in Schenectady County Expires Feb. 09, 20 o2 My Commission 4530481/916577090 3 of 3