On February 20, 2024 a
Pet Filed in Associate Ct
was filed
involving a dispute between
and
for AC Suit on Account
in the District Court of Howard County.
Preview
Electronically Filed - HOWARD - February 20, 2024 - 09:49 AM
24HD-AC00059
IN THE FOURTEENTH CIRCUIT COURT OF HOWARD COUNTY
DIVISION TWO
Howard County Ambulance District,
Plaintiff
v.
Beverly J Thomas
Defendant
PETITION FOR COLLECTION OF MEDICAL DEBT
COMES NOW, Plaintiff, Howard County Ambulance District, and for its cause of action
against Defendant states as follows:
1. Plaintiff, Howard County Ambulance District, is a political sub-division, created
under the laws of the State of Missouri, to provide ambulance service within Howard
County, Missouri. It is located entirely within Howard County, Missouri.
2. Defendant, Beverly J Thomas is a resident of Howard County, Missouri, residing at
190 County Road 105A, Fayette, MO 65248.
3. Defendant is indebted to Plaintiff for ambulance services provided on January 13,
2022 in Howard County, Missouri. The total value of the services provided is
$1,540.01
4. Plaintiff has made prior demand for payment by Defendant, but no satisfactory
recurring monthly payment has been received by Plaintiff.
5. After all offsets and credits due to Defendant, there remains a total balance due on
the account in the amount of $1,578.57
Page 1 of 2
Electronically Filed - HOWARD - February 20, 2024 - 09:49 AM
6. Pursuant to Howard County Ambulance District, Ordinance No. 2, Plaintiff is
entitled to recover its reasonable attorney fees incurred in the collection of this bill.
Plaintiff has incurred legal fees in the amount of $75.00.
THEREFORE, Plaintiff requests judgment in this matter against Defendant for the sum of
$1,578.57 with interest to accrue at the rate of 9% per year, plus attorney fees in the amount
of $75.00, and its costs in this matter, as provided by RSMO § 408.040.
Respectfully submitted:
Frank Robert Flaspohler, #62684
Attorney for Plaintiff
112 East Morrison Street
Post Office Box 329
Fayette, Missouri 65248
(660) 248-1040 telephone
office@showmelawyer.com
Page 2 of 2
Document Filed Date
February 20, 2024
Case Filing Date
February 20, 2024
Category
AC Suit on Account
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Electronically Filed - HOWARD - February 20, 2024 - 09:49 AM 24HD-AC00059 IN THE FOURTEENTH CIRCUIT COURT OF HOWARD COUNTY DIVISION TWO Howard County Ambulance District, Plaintiff v. Beverly J Thomas Defendant PETITION FOR COLLECTION OF MEDICAL DEBT COMES NOW, Plaintiff, Howard County Ambulance District, and for its cause of action against Defendant states as follows: 1. Plaintiff, Howard County Ambulance District, is a political sub-division, created under the laws of the State of Missouri, to provide ambulance service within Howard County, Missouri. It is located entirely within Howard County, Missouri. 2. Defendant, Beverly J Thomas is a resident of Howard County, Missouri, residing at 190 County Road 105A, Fayette, MO 65248. 3. Defendant is indebted to Plaintiff for ambulance services provided on January 13, 2022 in Howard County, Missouri. The total value of the services provided is $1,540.01 4. Plaintiff has made prior demand for payment by Defendant, but no satisfactory recurring monthly payment has been received by Plaintiff. 5. After all offsets and credits due to Defendant, there remains a total balance due on the account in the amount of $1,578.57 Page 1 of 2 Electronically Filed - HOWARD - February 20, 2024 - 09:49 AM 6. Pursuant to Howard County Ambulance District, Ordinance No. 2, Plaintiff is entitled to recover its reasonable attorney fees incurred in the collection of this bill. Plaintiff has incurred legal fees in the amount of $75.00. THEREFORE, Plaintiff requests judgment in this matter against Defendant for the sum of $1,578.57 with interest to accrue at the rate of 9% per year, plus attorney fees in the amount of $75.00, and its costs in this matter, as provided by RSMO § 408.040. Respectfully submitted: Frank Robert Flaspohler, #62684 Attorney for Plaintiff 112 East Morrison Street Post Office Box 329 Fayette, Missouri 65248 (660) 248-1040 telephone office@showmelawyer.com Page 2 of 2