Party Statement: PUNTA GORDA HMA LLC DBA SHOREPOINT HEALTH PUNTA GORDA vs. ARCHDEACON, ROBERT

• 
• 
• 
• 

						
                                
Preview
                                Filing # 194057766 E-Filed 03/14/2024 04:45:15 PM
                        IN THE COUNTY COURT, IN
                        THE TWENTIETH JUDICIAL CIRCUIT
                        IN AND FOR CHARLOTTE COUNTY, FLORIDA
                        CIVIL DIVISION
                        CASE NO: 24000455sP
         PUNTA GORDA HMA LLC DBA SHOREPOINT HEALTH
         PUNTA GORDA
         Plaintiff(s),
         -vs-
         ROBERT          ARCHDEACON
         Defendant(s).


                                                       COMPLAINT

                  Plaintiff(s), PUNTA GORDA HMA LLC DBA SHOREPOINT HEALTH PUNTA
        GORDA sue(s) Defendant, Robert Archdeacon, and allege(s):
                  1        This is an action for damages sounding of quantum meruit, which are $2,263.08,
        exclusive of interest, costs, and fees by virtue of which this Court has jurisdiction.
                  2.       Defendant   is a resident of Charlotte County, Florida and/or the subject matter
        hereof was transacted in Charlotte County, Florida.

                  3        On one or more dates, with the last date being March 28, 2023, Plaintiff rendered

        medical treatment for Defendant and/or Defendant's lawful dependent.
                  4        Defendant had knowledge of, and/or acquiesced in, the rendering of the medical
         services by Plaintiff.
                  5        Defendant was aware that Plaintiff expected to be compensated for the medical
         services rendered by Plaintiff.
                  6        Defendant has been unjustly enriched by receiving the medical services rendered
        by Plaintiff and it would be inequitable        for Defendant   to retain the benefit of such medical
         services without paying fair value for the same.
                  7        Defendant failed to pay on demand.
                  8        Plaintiff would   welcome   settlement either by lump   sum   or monthly   payment
        arrangements by contacting the law firm at 866-603-8129. Defendant must still comply with all
        of the Court’s requirements.
                  WHEREFORE, Plaintiff prays this Honorable Court to enter a Judgment against
        Defendant, in favor of the Plaintiff, for the principal amount plus court costs.
                  In compliance with Federal Law you are advised that this is an attempt to collect a debt
        and any information obtained will be used for that purpose.
                  DATED     at Cocoa, Brevard County, Florida, March 4, 2024.
LOTANE & ASSOCIATES, P.A.
       Attorneys At Law

       4s Troy R. Lotane
        TROY R. LOTANE
        Florida Bar No: 163015
       JOHN WILHELM
       Florida Bar No: 17157
       ANTHONY STEELE
       Florida Bar No: 74810
       TYESHA WARE
       Florida Bar No: 127460
       BERNADINE PHILIPPE
       Florida Bar No: 93626
       M’ISHA HUGHES
       Florida Bar No: 1038713
       MELISSA ROBERTS
       Florida Bar No: 370703
       Rule 2.515 Designated Service Email:
       Service@Lotane.com
       1980 Michigan Avenue
       Cocoa, Florida 32922
       (321) 636-4861 / (800) 807-3334
       Attorneys for Plaintiff(s)




AUNT