On February 21, 2024 a
Complaint,Petition
was filed
involving a dispute between
Community Care Physicians, P.C.,
and
Amber Rose Pembroke,
for Other Matters - Contract - Other
in the District Court of Otsego County.
Preview
FILED: OTSEGO COUNTY CLERK 02/21/2024 10:34 AM INDEX NO. EF2024-138
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF OTSEGO
COMMUNITY CARE PHYSICIANS, P.C.
711 TROY SCHENECTDY RD
LATHAM, NY 12110
SUMMONS
Plaintiff,
Index No.
Date Filed
AMBER ROSE PEMBROKE
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 plaintiffs 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 OTSEGO.
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:
AMBER ROSE PEMBROKE
60 E JAMES ST
Richfield Spring, NY 13439
NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
1006942170/911705720
1 of 3
FILED: OTSEGO COUNTY CLERK 02/21/2024 10:34 AM INDEX NO. EF2024-138
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF OTSEGO
COMMUNITY CARE PHYSICIANS, P.C.
VERIFIED
COMPLAINT
Plaintiff,
Index No.
AMBER ROSE PEMBROKE
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 September 20, 2022 to October 5, 2022, 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 counsel's
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 $890.75.
WHEREFORE , the plaintiff demands judgment against the defendant in the sum of $890.75 with interest
from October 5, 2022, plus the costs and disbursements of the action and for such other, further or different relief as
to this Court may deem just.
DATED: h (A /^
(A
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: OTSEGO COUNTY CLERK 02/21/2024 10:34 AM INDEX NO. EF2024-138
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2024
SVC-H-3 (81)
SUPREME COURT OF THE STATE OF NEW YORK :
: ss. :
COUNTY OF OTSEGO
COMMUNITY CARE PHYSICIANS, P.C.
711 TROY SCHENECTDY RD
LATHAM, NY 12110 Plaintiff,
VERIFICATION
AMBER ROSE PEMBROKE 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 's
day of ,20
N Public
Mary Jo Teresco
Notary Public
State of New York
Qualified in Schenectady County
My Commission Expires Feb.09, 20
1006942170/911705720
3 of 3
Document Filed Date
February 21, 2024
Case Filing Date
February 21, 2024
Category
Other Matters - Contract - Other
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FILED: OTSEGO COUNTY CLERK 02/21/2024 10:34 AM INDEX NO. EF2024-138 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF OTSEGO COMMUNITY CARE PHYSICIANS, P.C. 711 TROY SCHENECTDY RD LATHAM, NY 12110 SUMMONS Plaintiff, Index No. Date Filed AMBER ROSE PEMBROKE 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 plaintiffs 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 OTSEGO. 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: AMBER ROSE PEMBROKE 60 E JAMES ST Richfield Spring, NY 13439 NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1006942170/911705720 1 of 3 FILED: OTSEGO COUNTY CLERK 02/21/2024 10:34 AM INDEX NO. EF2024-138 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF OTSEGO COMMUNITY CARE PHYSICIANS, P.C. VERIFIED COMPLAINT Plaintiff, Index No. AMBER ROSE PEMBROKE 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 September 20, 2022 to October 5, 2022, 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 counsel's 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 $890.75. WHEREFORE , the plaintiff demands judgment against the defendant in the sum of $890.75 with interest from October 5, 2022, plus the costs and disbursements of the action and for such other, further or different relief as to this Court may deem just. DATED: h (A /^ (A 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: OTSEGO COUNTY CLERK 02/21/2024 10:34 AM INDEX NO. EF2024-138 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2024 SVC-H-3 (81) SUPREME COURT OF THE STATE OF NEW YORK : : ss. : COUNTY OF OTSEGO COMMUNITY CARE PHYSICIANS, P.C. 711 TROY SCHENECTDY RD LATHAM, NY 12110 Plaintiff, VERIFICATION AMBER ROSE PEMBROKE 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 's day of ,20 N Public Mary Jo Teresco Notary Public State of New York Qualified in Schenectady County My Commission Expires Feb.09, 20 1006942170/911705720 3 of 3