On February 27, 2024 a
Complaint,Petition
was filed
involving a dispute between
Mohawk Valley Health System,
and
Theresa Bell,
for Other Matters - Contract - Other
in the District Court of Herkimer County.
Preview
FILED: HERKIMER COUNTY CLERK 02/27/2024 04:06 PM INDEX NO. EF2024-111356
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/27/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF HERKIMER
MOHAWK VALLEY HEALTH SYSTEM
220'9 GENESEE ST
UTICA, NY 13503
SUMMONS
Plaintiff,
Index No.
Date Filed
THERESA BELL
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 HERKIMER.
Dated:h 22320 3
Melissa M. Tobrocke, Esq.
ORDD LAW, LLP
Attorneys for the Plaintiff
19 Executive Park Dr.
Clifton Park, New York 12065
(518) 383-4876
FORPROCESS SERVERONLY
DEFENDANT 1: DEFENDANT 2:
THERESA BELL
893 NEWPORT GRAY RD
NEWPORT, NY 13416
NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
1005844622
1 of 3
FILED: HERKIMER COUNTY CLERK 02/27/2024 04:06 PM INDEX NO. EF2024-111356
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/27/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF HERKIMER
MOHAWK VALLEY HEALTH SYSTEM
VERIFIED
COMPLAINT
Plaintiff,
Index No.
THERESA BELL
Defendant(s).
The plaintiff alleges:
1. The Plaintiff is a domestic corporation authorized to establish and maintain a hospital to render hospital
and medical 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 December 3, 2021 to December 12, 2022, the plaintiff, at the express or implied request of the
defendant, rendered hospital and/or 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 address
or the address provided 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 $2,090.50.
WHEREFORE , the plaintiff demands judgment against the defendant in the sum of $2,090.50 with
interest from December 12, 2022, plus the costs and disbursements of the action and for such other, further or
different relief as to this Court may deem just.
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: HERKIMER COUNTY CLERK 02/27/2024 04:06 PM INDEX NO. EF2024-111356
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/27/2024
SV,C-H-3 (81)
SUPREME COURT OF THE STATE OF NEW YORK :
: ss. :
COUNTY OF HERKIMER
MOHAWK VALLEY HEALTH SYSTEM
2209 GENESEE ST
UTICA, NY 13503 Plaintiff,
VERIFICATION
THERESA BELL 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 hospital to render hospital and medical 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.
KIMBERLY ALLEN
DIRECTOR OF PATIENT AC UNTS
Sworn to before me this
day of ,20
Notary Pubhc
Melissa M. Tobrecke
Notary Public, State ofNewYork
No. 02TO6149328 .
Qualified in Saratoga Cou
Commission Expires 7 / 10 /
1005844622
3 of 3
Document Filed Date
February 27, 2024
Case Filing Date
February 27, 2024
Category
Other Matters - Contract - Other
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Preview
FILED: HERKIMER COUNTY CLERK 02/27/2024 04:06 PM INDEX NO. EF2024-111356 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/27/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF HERKIMER MOHAWK VALLEY HEALTH SYSTEM 220'9 GENESEE ST UTICA, NY 13503 SUMMONS Plaintiff, Index No. Date Filed THERESA BELL 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 HERKIMER. Dated:h 22320 3 Melissa M. Tobrocke, Esq. ORDD LAW, LLP Attorneys for the Plaintiff 19 Executive Park Dr. Clifton Park, New York 12065 (518) 383-4876 FORPROCESS SERVERONLY DEFENDANT 1: DEFENDANT 2: THERESA BELL 893 NEWPORT GRAY RD NEWPORT, NY 13416 NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1005844622 1 of 3 FILED: HERKIMER COUNTY CLERK 02/27/2024 04:06 PM INDEX NO. EF2024-111356 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/27/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF HERKIMER MOHAWK VALLEY HEALTH SYSTEM VERIFIED COMPLAINT Plaintiff, Index No. THERESA BELL Defendant(s). The plaintiff alleges: 1. The Plaintiff is a domestic corporation authorized to establish and maintain a hospital to render hospital and medical 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 December 3, 2021 to December 12, 2022, the plaintiff, at the express or implied request of the defendant, rendered hospital and/or 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 address or the address provided 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 $2,090.50. WHEREFORE , the plaintiff demands judgment against the defendant in the sum of $2,090.50 with interest from December 12, 2022, plus the costs and disbursements of the action and for such other, further or different relief as to this Court may deem just. 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: HERKIMER COUNTY CLERK 02/27/2024 04:06 PM INDEX NO. EF2024-111356 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/27/2024 SV,C-H-3 (81) SUPREME COURT OF THE STATE OF NEW YORK : : ss. : COUNTY OF HERKIMER MOHAWK VALLEY HEALTH SYSTEM 2209 GENESEE ST UTICA, NY 13503 Plaintiff, VERIFICATION THERESA BELL 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 hospital to render hospital and medical 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. KIMBERLY ALLEN DIRECTOR OF PATIENT AC UNTS Sworn to before me this day of ,20 Notary Pubhc Melissa M. Tobrecke Notary Public, State ofNewYork No. 02TO6149328 . Qualified in Saratoga Cou Commission Expires 7 / 10 / 1005844622 3 of 3