Preview
FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ONONDAGA
Index No.:
BANKERS HEALTHCARE GROUP, LLC Date Filed:
201 Solar Street
Syracuse, New York 13204 Plaintiff designates Onondaga
Plaintiff, County as the place of trial
-vs-
The basis of venue is
MARY B. ARCE D/B/A MARY B. ARCE, R.N. principle place of
& MARY B. ARCE plaintiff's business
6129 Rolkingham Lane
Orangevale, California 95662
Defendants.
SUMMONS
Plaintiff maintains an office
for the conduct of business at
Syracuse, County of
Onondaga
New York 13204
TO THE ABOVE NAMED DEFENDANTS: MARY B. ARCE D/B/A MARY B. ARCE, R.N.
& MARY B. ARCE
YOU ARE HEREBY SUMMONED to answer the complaint in this action and serve a
copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff's attorneys within twenty (20) days after the service of this summons,
exclusive of the day of service (or within 30 days after the service is complete if this summons is
not personally delivered to you within the State of New York); and in case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded herein.
Dated: February 23, 2021
Christopher J. Cali, Esq.
CJC Law Office
201 Solar Street
Syracuse, New York 13204
Telephone: (315) 877-9360
Fax: (315) 314-8736
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DEFENDANTS'
ADDRESSES:
MARY B. ARCE D/B/A MARY B. ARCE, R.N.
6129 Rolkingham Lane
Orangevale, California 95662
MARY B. ARCE
6129 Rolkingham Lane
Orangevale, California 95662
NOTICE: The nature of this action is for (1) breach of Financing Agreement, and (2) breach
of Personal Guaranty.
The relief sought is judgment.
UPON YOUR FAILURE TO APPEAR, JUDGMENT WILL BE TAKEN AGAINST YOU
BY DEFAULT FOR THE SUM OF $48,927.24 TOGETHER WITH INTEREST
THEREON, REASONABLE ATTORNEYS FEES, AND THE COST OF THIS ACTION.
PURSUANT TO 15 U.S.C. 1692 ET SEQ.,
YOU ARE HEREBY NOTIFIED THAT THIS CORRESPONDENCE
IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
YOU ARE HEREBY ADVfSED THAT:
1. UNLESS YOU, WITHEN THIRTY (30) DAYS AFTER RECEIPT OF THIS NOTICE, D1SPUTETHE VALIDITY OF THIS DEBT, OR ANY
PORTION THEREOF, THIS DEBT WILL BE ASSUMED TO BE VALID BY US.
2. IF YOUNOTIFY USIN WRITING WITHIN THE THIRTY (30) DAY PERIOD THAT THE DEBT ORANY PORTION THEREOFIS DISPUTED,
WE WILL OBTAIN VERIFICATION OF THE DEBT OR A COPYOF THE JUDGMENT AGAINST YOUAND MAIL SUCH VERIFICATION OR
COPYTO YOU.
3. UPON YOURWRITTEN REQUESTWITHIN THE THIRTY (30) DAY PERIOD, WE WILL PROVIDEYOU WITH THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENTCREDITOR.
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ONONDAGA
BANKERS HEALTHCARE GROUP, LLC
Plaintiff,
vs. VERIFIED COMPLAINT
MARY B. ARCE D/B/A MARY B. ARCE, R.N.
& MARY B. ARCE
Defendants.
The plaintiff, Bankers Healthcare Group, LLC (hereinafter referred to as "BHG"), complains of
MARY B. ARCE D/B/A MARY B. ARCE, R.N. & MARY B. ARCE, defendants and alleges as
follows:
1. That at alltimes hereinafter mentioned, BHG is now and at allrelevant times herein was
(i)a Florida corporation with principal offices at 201 Solar Street, Syracuse, New York
13204, and 10234 West State Road 84, Davie, Florida 33324, and (ii)authorized to do
business in the State of New York.
2. That at all times hereinafter mentioned, upon information and belief, that MARY B.
ARCE D/B/A MARY B. ARCE, R.N. is a California Sole Proprietorship with its
principle place of business located at 6129 Rolkingham Lane, Orangevale, California
95662.
3. That at all times hereinafter mentioned, upon information and belief, that MARY B.
ARCE is an adult resident citizen of the State of California, with a residence located at
6129 Rolkingham Lane, Orangevale, California 95662.
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AS AND FOR A FIRST SEPARATE AND DISTINCT
CAUSE OF ACTION, PLAINTIFF ALLEGES:
(BREACH OF FINANCING AGREEMENT)
4. That upon information and belief, on or about December 8, 2017, MARY B. ARCE
D/B/A MARY B. ARCE, R.N., made, executed and delivered to BHG a Promissory Note
(the "Note") for the total sum of One Hundred Sixteen Thousand, Fourteen DOLLARS
and Eight CENTS ($116,014.08). A true, accurate, correct and genuine copy of the Note
"A"
is attached hereto as Exhibit and is incorporated by reference as though fully set
forth herein.
5. That upon information and belief, pursuant to the terms of the Note, MARY B. ARCE
D/B/A MARY B. ARCE, R.N. agreed to make Ninety-Six (96) monthly payments of
$1,208.48 each, commencing on January 15, 2018.
6. That upon information and belief, On or about December 8, 2017, MARY B. ARCE
D/B/A MARY B. ARCE, R.N., made, execute and delivered a written Security
Agreement (the "Security Agreement"), which Security Agreement provided a security to
BHG for MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s payment and performance
obligations under the terms and conditions of the Note. The Security Agreement
provided BHG a security interest in all the right, titleand interest of the Debtor in and to
Accounts Receivable, Inventory, Instruments, Equipment, Intangibles, Accounts, Chattel
Paper, Good Will, Fixtures, Specific Property, and All Property of Debtor and all
proceeds thereof (collectively, the "Collateral"). A true, accurate, correct and genuine
"A"
copy of the Security Agreement is attached hereto as Exhibit and is incorporated by
reference as though fully set forth herein.
7. That the Financing Agreement provides that any payment due and owing thereunder not
made when due shall constitute an Event of Default. Moreover, the Note explicitly
provides that any payment not made when due shall bear late charges thereon calculated
at the rate of ten (10%) per month, but not to exceed the highest rate permitted by
relevant law.
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8. That the Financing Agreement further provide that upon Event of Default
any thereafter,
BHG may accelerate all indebtedness due and owing under these Notes with MARY B.
ARCE D/B/A MARY B. ARCE, R.N..
9. That MARY B. ARCE D/B/A MARY B. ARCE, R.N. has failed to comply with the clear
and unambiguous terms and conditions of the Financing Agreement by, among other
things, failing to make timely payments due and owing to BHG thereunder.
10. That MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s, failure to make payments to
BHG constitutes an Event of Default pursuant to page 2, Default Section, of the
Financing Agreement.
11. That upon Default, BHG provided a Demand Letter giving Notice of Default to MARY
B. ARCE D/B/A MARY B. ARCE, R.N. addressed to the attention of itsprinciple that
MARY B. ARCE. A true, accurate, and correct copy of the Demand Letter is attached
"B"
hereto as Exhibit and is incorporated by reference as though fully set forth herein.
Despite BHG's demand, MARY B. ARCE D/B/A MARY B. ARCE, R.N., failed to
tender payment to BHG to cure the full Default under the Financing Agreement.
12. That as a result of MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s default, BHG
declared the entire indebtedness arising under the Financing Agreement to be
immediately due and payable. Accordingly, as of February 23, 2021, there isjustly due
and owing to BHG by MARY B. ARCE D/B/A MARY B. ARCE, R.N., an amount equal
to,not less than $48,927.24, inclusive of late charges, per diem interest, and costs
(hereinafter the "Indebtedness").
13. That the Indebtedness, as of February 23, 2021, is separately itemized as follows:
Principal Balance Due Upon Default: $48,602.81
Per Diem Interest ($22.62/Day) $203.58 (February 15, 2021 through
February 23, 2021)
Late Charges: $120.85
Total (February 23, 2021) $48,927.24
14. That BHG has performed all conditions, covenants and promises required of itunder the
terms and conditions of the Financing Agreement.
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AS AND FOR A SECOND SEPARATE AND DISTINCT
CAUSE OF ACTION, PLAINTIFF ALLEGES:
(BREACH OF PERSONAL GUARANTY)
15. Plaintiff repeats and re-alleges the allegations of paragraphs 1 through 14 above as
if set forth herein at length.
16. That on or about December 8, 2017, that MARY B. ARCE made, executed and
delivered a written Personal Guaranty (the "Guaranty") in favor of BHG, pursuant to
which MARY B. ARCE absolutely guaranteed full payment and full performance of
MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s obligations under the Financing
Agreement. As well as payment of all amounts owed to BHG then and at any future
time. A true, accurate, correct and genuine copy of the Guaranty is attached hereto as
"A"
Exhibit and is incorporated by reference as though fully set forth herein.
17. That in the Guaranty, that MARY B. ARCE expressly agreed to "absolutely,
irrevocably and unconditionally promises to pay and guaranty the full and prompt
payment of all of the debt...when due...without limitation all principal, accrued
interest, attorney's fees and collection and court costs that may become due from
Debt."
Debtor to Creditor in collecting the
18. That BHG provided notice of MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s
default to that MARY B. ARCE. A true, accurate, genuine and correct copy of the
"B"
Guarantor Notice of Default is attached hereto as Exhibit and is incorporated by
reference as though fully set forth herein. Despite BHG's notice of MARY B. ARCE
D/B/A MARY B. ARCE, R.N.'s default and its demand that MARY B. ARCE comply
with their obligations under the Guaranty, that MARY B. ARCE have failed to tender
the full amount of the indebtedness to BHG as they are required to do.
19. That BHG has performed all conditions, covenants and promises required of it under
the terms and conditions of the Guaranty.
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20. WHEREFORE, plaintiff demands judgment against the defendants as follows:
A. On the First Cause of Action, judgment against defendants in the sum of $48,927.24
together with legal interest thereon.
B. On the Second Cause of Action, judgment against defendants in the sum of
$48,927.24 together with legal interest thereon.
C. Costs and disbursements of this action.
D. That the plaintiff have such other and further relief as the Court deems equitable
and proper.
DATED: February 23, 2021
Christopher J. Cali, Esq.
CJC Law Office
201 Solar Street
Syracuse, New York 13204
Telephone: (315) 877-9360
Fax: (315) 314-8736
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Preview
FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ONONDAGA Index No.: BANKERS HEALTHCARE GROUP, LLC Date Filed: 201 Solar Street Syracuse, New York 13204 Plaintiff designates Onondaga Plaintiff, County as the place of trial -vs- The basis of venue is MARY B. ARCE D/B/A MARY B. ARCE, R.N. principle place of & MARY B. ARCE plaintiff's business 6129 Rolkingham Lane Orangevale, California 95662 Defendants. SUMMONS Plaintiff maintains an office for the conduct of business at Syracuse, County of Onondaga New York 13204 TO THE ABOVE NAMED DEFENDANTS: MARY B. ARCE D/B/A MARY B. ARCE, R.N. & MARY B. ARCE YOU ARE HEREBY SUMMONED to answer the complaint in this action and serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff's attorneys within twenty (20) days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. Dated: February 23, 2021 Christopher J. Cali, Esq. CJC Law Office 201 Solar Street Syracuse, New York 13204 Telephone: (315) 877-9360 Fax: (315) 314-8736 1 of 7 FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021 DEFENDANTS' ADDRESSES: MARY B. ARCE D/B/A MARY B. ARCE, R.N. 6129 Rolkingham Lane Orangevale, California 95662 MARY B. ARCE 6129 Rolkingham Lane Orangevale, California 95662 NOTICE: The nature of this action is for (1) breach of Financing Agreement, and (2) breach of Personal Guaranty. The relief sought is judgment. UPON YOUR FAILURE TO APPEAR, JUDGMENT WILL BE TAKEN AGAINST YOU BY DEFAULT FOR THE SUM OF $48,927.24 TOGETHER WITH INTEREST THEREON, REASONABLE ATTORNEYS FEES, AND THE COST OF THIS ACTION. PURSUANT TO 15 U.S.C. 1692 ET SEQ., YOU ARE HEREBY NOTIFIED THAT THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. YOU ARE HEREBY ADVfSED THAT: 1. UNLESS YOU, WITHEN THIRTY (30) DAYS AFTER RECEIPT OF THIS NOTICE, D1SPUTETHE VALIDITY OF THIS DEBT, OR ANY PORTION THEREOF, THIS DEBT WILL BE ASSUMED TO BE VALID BY US. 2. IF YOUNOTIFY USIN WRITING WITHIN THE THIRTY (30) DAY PERIOD THAT THE DEBT ORANY PORTION THEREOFIS DISPUTED, WE WILL OBTAIN VERIFICATION OF THE DEBT OR A COPYOF THE JUDGMENT AGAINST YOUAND MAIL SUCH VERIFICATION OR COPYTO YOU. 3. UPON YOURWRITTEN REQUESTWITHIN THE THIRTY (30) DAY PERIOD, WE WILL PROVIDEYOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENTCREDITOR. 2 of 7 FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ONONDAGA BANKERS HEALTHCARE GROUP, LLC Plaintiff, vs. VERIFIED COMPLAINT MARY B. ARCE D/B/A MARY B. ARCE, R.N. & MARY B. ARCE Defendants. The plaintiff, Bankers Healthcare Group, LLC (hereinafter referred to as "BHG"), complains of MARY B. ARCE D/B/A MARY B. ARCE, R.N. & MARY B. ARCE, defendants and alleges as follows: 1. That at alltimes hereinafter mentioned, BHG is now and at allrelevant times herein was (i)a Florida corporation with principal offices at 201 Solar Street, Syracuse, New York 13204, and 10234 West State Road 84, Davie, Florida 33324, and (ii)authorized to do business in the State of New York. 2. That at all times hereinafter mentioned, upon information and belief, that MARY B. ARCE D/B/A MARY B. ARCE, R.N. is a California Sole Proprietorship with its principle place of business located at 6129 Rolkingham Lane, Orangevale, California 95662. 3. That at all times hereinafter mentioned, upon information and belief, that MARY B. ARCE is an adult resident citizen of the State of California, with a residence located at 6129 Rolkingham Lane, Orangevale, California 95662. 3 of 7 FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021 AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE OF ACTION, PLAINTIFF ALLEGES: (BREACH OF FINANCING AGREEMENT) 4. That upon information and belief, on or about December 8, 2017, MARY B. ARCE D/B/A MARY B. ARCE, R.N., made, executed and delivered to BHG a Promissory Note (the "Note") for the total sum of One Hundred Sixteen Thousand, Fourteen DOLLARS and Eight CENTS ($116,014.08). A true, accurate, correct and genuine copy of the Note "A" is attached hereto as Exhibit and is incorporated by reference as though fully set forth herein. 5. That upon information and belief, pursuant to the terms of the Note, MARY B. ARCE D/B/A MARY B. ARCE, R.N. agreed to make Ninety-Six (96) monthly payments of $1,208.48 each, commencing on January 15, 2018. 6. That upon information and belief, On or about December 8, 2017, MARY B. ARCE D/B/A MARY B. ARCE, R.N., made, execute and delivered a written Security Agreement (the "Security Agreement"), which Security Agreement provided a security to BHG for MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s payment and performance obligations under the terms and conditions of the Note. The Security Agreement provided BHG a security interest in all the right, titleand interest of the Debtor in and to Accounts Receivable, Inventory, Instruments, Equipment, Intangibles, Accounts, Chattel Paper, Good Will, Fixtures, Specific Property, and All Property of Debtor and all proceeds thereof (collectively, the "Collateral"). A true, accurate, correct and genuine "A" copy of the Security Agreement is attached hereto as Exhibit and is incorporated by reference as though fully set forth herein. 7. That the Financing Agreement provides that any payment due and owing thereunder not made when due shall constitute an Event of Default. Moreover, the Note explicitly provides that any payment not made when due shall bear late charges thereon calculated at the rate of ten (10%) per month, but not to exceed the highest rate permitted by relevant law. 4 of 7 FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021 8. That the Financing Agreement further provide that upon Event of Default any thereafter, BHG may accelerate all indebtedness due and owing under these Notes with MARY B. ARCE D/B/A MARY B. ARCE, R.N.. 9. That MARY B. ARCE D/B/A MARY B. ARCE, R.N. has failed to comply with the clear and unambiguous terms and conditions of the Financing Agreement by, among other things, failing to make timely payments due and owing to BHG thereunder. 10. That MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s, failure to make payments to BHG constitutes an Event of Default pursuant to page 2, Default Section, of the Financing Agreement. 11. That upon Default, BHG provided a Demand Letter giving Notice of Default to MARY B. ARCE D/B/A MARY B. ARCE, R.N. addressed to the attention of itsprinciple that MARY B. ARCE. A true, accurate, and correct copy of the Demand Letter is attached "B" hereto as Exhibit and is incorporated by reference as though fully set forth herein. Despite BHG's demand, MARY B. ARCE D/B/A MARY B. ARCE, R.N., failed to tender payment to BHG to cure the full Default under the Financing Agreement. 12. That as a result of MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s default, BHG declared the entire indebtedness arising under the Financing Agreement to be immediately due and payable. Accordingly, as of February 23, 2021, there isjustly due and owing to BHG by MARY B. ARCE D/B/A MARY B. ARCE, R.N., an amount equal to,not less than $48,927.24, inclusive of late charges, per diem interest, and costs (hereinafter the "Indebtedness"). 13. That the Indebtedness, as of February 23, 2021, is separately itemized as follows: Principal Balance Due Upon Default: $48,602.81 Per Diem Interest ($22.62/Day) $203.58 (February 15, 2021 through February 23, 2021) Late Charges: $120.85 Total (February 23, 2021) $48,927.24 14. That BHG has performed all conditions, covenants and promises required of itunder the terms and conditions of the Financing Agreement. 5 of 7 FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021 AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION, PLAINTIFF ALLEGES: (BREACH OF PERSONAL GUARANTY) 15. Plaintiff repeats and re-alleges the allegations of paragraphs 1 through 14 above as if set forth herein at length. 16. That on or about December 8, 2017, that MARY B. ARCE made, executed and delivered a written Personal Guaranty (the "Guaranty") in favor of BHG, pursuant to which MARY B. ARCE absolutely guaranteed full payment and full performance of MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s obligations under the Financing Agreement. As well as payment of all amounts owed to BHG then and at any future time. A true, accurate, correct and genuine copy of the Guaranty is attached hereto as "A" Exhibit and is incorporated by reference as though fully set forth herein. 17. That in the Guaranty, that MARY B. ARCE expressly agreed to "absolutely, irrevocably and unconditionally promises to pay and guaranty the full and prompt payment of all of the debt...when due...without limitation all principal, accrued interest, attorney's fees and collection and court costs that may become due from Debt." Debtor to Creditor in collecting the 18. That BHG provided notice of MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s default to that MARY B. ARCE. A true, accurate, genuine and correct copy of the "B" Guarantor Notice of Default is attached hereto as Exhibit and is incorporated by reference as though fully set forth herein. Despite BHG's notice of MARY B. ARCE D/B/A MARY B. ARCE, R.N.'s default and its demand that MARY B. ARCE comply with their obligations under the Guaranty, that MARY B. ARCE have failed to tender the full amount of the indebtedness to BHG as they are required to do. 19. That BHG has performed all conditions, covenants and promises required of it under the terms and conditions of the Guaranty. 6 of 7 FILED: ONONDAGA COUNTY CLERK 02/26/2021 08:37 AM INDEX NO. 001727/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/26/2021 20. WHEREFORE, plaintiff demands judgment against the defendants as follows: A. On the First Cause of Action, judgment against defendants in the sum of $48,927.24 together with legal interest thereon. B. On the Second Cause of Action, judgment against defendants in the sum of $48,927.24 together with legal interest thereon. C. Costs and disbursements of this action. D. That the plaintiff have such other and further relief as the Court deems equitable and proper. DATED: February 23, 2021 Christopher J. Cali, Esq. CJC Law Office 201 Solar Street Syracuse, New York 13204 Telephone: (315) 877-9360 Fax: (315) 314-8736 7 of 7