Preview
FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700
088
NYSCEF
SUPREME
DOC. COURT
NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 03/30/2021
v2-1(A81)
COUNTY OF COLUMBIA
---------------------------------------- SUMMONS AND VERIFIED COMPLAINT
CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD
Index No.
Date Filed:
Plaintiff(s), The basis of the venue for trial
designated is;defendant(s) resides
AGAINST in COLUMBIA County.
SUSAN MCAVOY Plaintiff's place of business is
at:283 MOUNTAIN VIEW RD
COPAKE ,NY
103 ADAMS RD 12516
COPAKE ,NY 125161012 . COLUMBIA County
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 Plaintiff s Attorney within 20 days after service
of this summons, exclusive of the day of service, or if service of this
summons is made by any means other than by personal delivery to you within
the state, within 30 days after such service is complete. In case of vour
failure to answer, judgment will be taken against you by default for the
relief demanded in the complaint.
Pa L rks, Es
Attor ey for PlaintiÎf(s)
Dated: 3/03/21 Law Offices of Paul L. Marks, P L.L.C.
Newburgh, New York 299 N2 Plank Road - Suite 104
Newburgh, New York 12550
[845) 561-6917
VERIFIED-AFFIRMED COMPLAINT
1. Plaintiff(s) is.a NEW YORK corporation and is authorized
to do -business in the State of New York
2. Uoon information and belief Defendant(s) resides in the within county
at the address shown above.
AS AND FOR A FIRST CAUSE OF ACTION - ACCOUNT STATED
3. Defendant(s) owe plaintiff(s) for medical and/or transportation services
accepted upon an account stated as of 3/16/19 for a sum certain in the
principal amount of $1,820.74 together with interest from 3/16/19
in the amount of $336.84
AS D FOR A,SECOND CAUSE OF ACTION - BREACH OF CONTRACT
4. Defendant(s owe plaintiff(s) for breach of contract to pay for medical
and/or transportation services provided for and accepted by defendant(s)
as of 3/16/19 for the sum certain of $1,820.74 together with interest
from 3/16/19 in the. amount of $336.84
AS AND FOR A. THIRD CAUSE OF ACTION - UNJUST ENRICHMENT
5. Plaintiff(s) repeats, reiterates and realleges each and every allegation
contained in paragraphs 1 through 4 herein with the same force and effect
as if fully set forth at length herein.
6. By reason of the foregoing, Defendant(s)
SUSAN MCAVOY
have been unjustly enriched in the sum of $1,820.74 , which has been and
still due and owing to the Plaintiff(s) for the benefits conferred u n
them by the Plaintiff(s) and accepted and retained by these Defendan Îs).
7. Demand has been made for payment herein for the above causes of action,
howevere Defendant(s) has refused to tender any payment on this account.
WWRRRFORE, plaintiff(s) demands judgment against defendant(s) on each of the
above causes of action in the amount of $2,157.58 together with interest
from 3/03/21 plus costs and disbursements of this action.
Dated: 3/03/21 L w Offi s of Paul L. Marks, P.L.L.C.
Newburgh, New York 2 N. ank Road - Suite 104
Newburgh, -New York 12550
(845) 561-6917
This is an attempt to collect a debt and
any information obtainea will be used for that purpose.
FILED 3/30/2021 1 of 5
FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700
066
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021
v2.1(D82)
CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD
- AGAINST -
SUSAN MCAVOY
103 ADAMS RD
COPAKE ,NY 125161012
Principal Due - $1,820.74
Interest - $336.84
Cost Statute - $200 . 00
.by
Service of Summons - $47.24
Fee for INDEX No. - $210.00
_____________
TOTAL DUE - $2,614.82
=========
2 of 5
FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021
LAW OFFICES OF PAUL L. MARKS, P.L.L.C.
299 N PLANK RD STE 104
NEWBURGH, NY 12550
(845) 561-6917
02/17/21
CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD
JOANN PILKINGTON
PO BOX 327 FILE# 191373254
COPAKE, NY 12516
With your permission, the Law Offices of Paul L. Marks, P.L.L.C. will
institute legal action on your behalf against the following account:
ACCOUNT #/S NAME AND ADDRESS
0177 SUSAN MCAVOY
$1,820.74
SERVICE DATE 103 ADAMS RD
03/16/19 COPAKE, NY 12516-1012
IT IS IMPORTANT THAT YOU:
1. Return this letter to our office and please indicate the correct
balance.
2. Please DO NOT accept payments from the debtor, refer him to our office.
3. Mark your records to indicate that this account has been referred
to the attorney.
VERIFICATION
STATE OF NEW YORK: COUNTY OF D/2Ó
JOANN PILKINGTON being duly sworn, deposes and says:
I am the /}(6/ of
CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD a corporation, one of the parties
to the action: I have read the annexed Complaint, know the contents thereof
and the same are true to my knowledge, except those matters therein which
are stated to be alleged on information and belief, and as to those matters
I believe true. My belief, as to those matters therein not stated upon
knowledge, is based upon the following: books, papers records in my
possession.
worn to before me on o
. ERIN F. CONKLIN
NotaryPublic,StateOfNewY
Reg.No.01CO6231048
Con
3 of 5
FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021
ATTORNEY CERTIFICATION
I,PAUL L. MARKS, ESQ., HEREBY CERTIFY, under the penalty of perjury
and as an officer of the Court I have no knowledge that.the substance of any factual
submissions contained in this document is false. This Certification is based solely and
exclusively upon information provided by the client, and upon the client's certification to
the undersigned attorney that such information is not false, and is not made based upon
by the undersigned attorney or anyone acting on behalf of said attorney.
PLEASE TAKE FURTHER NOTICE, that this Certification is made by the
attorney as an officer of the Court and is directly solely and exclusively to the Court in
accordance with 22 NYCRR 202.16 (e) and is expressly not directed or extended to the
opposing party herein.
PLEASE TAKE FURTHER NOTICE that the opposing party may not and should
not rely upon this Attorney Certification in assessing the truth or validity of the
information contained in the annexed document. The credibility of this submission is no
greater than the credibility of the client represented by the undersigned attorney and the
opposing party should give this document no greater credence because itbears this
Attorney Certification.
Dated:
P L L.MA S, ESQ,
4 of 5
FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021
CBHV (L)E(G)AL APPLICATION V2.0 Time: 16:24:41
------ ********************* Date: 3/25/21
NJLG16 * SlM0NS PROCESSED * 6
Copy
* SUPREK C0lRT *
*********************
ACCOUNT INTEREST INTR MR SlM0NS
CO CASE# PLAINTIFF(S) (LIST ALL (N SlM10NS) BALANCE FRM DATE DAYS RATE INTEREST
__ _________ ___________-___-____ _____________________________ ------.___ -------- -- ______ __________
01 191373254 CLAUSSON PAH1T CCM1UNITY RESCUE SQUAD 1,820.74 3/16/19 740 .00025 336.84
283 K)UNTAIN VIEW RD
CDPAKE NY 12516 œLitiBIA
TOTAL SlI+DNS INTEREST; 336.84
PLAINTIFF(S) CLASS:. A - AMBULANCE SERVICES OSTS BY STATUTE: 200.00
SERVICE 0F SlI†INS: 47,24
QUNTY INDEX NltiBER: 210,00
TOTAL SU‡DNS COSTS: 457.24
TOTAL OF ALL (DPANIONATED BALANCES: 1,820.74 TOTAL SlM10NS: 2 614.ÏÖ
T CASE# DEFENDANT(S) DTE ENTD SlMES CITY SlMONS COUNTY
01 191373254 SUSAN MCAVOY 3/25/21 COLlNBIA H0Æ0AER: Y
103 AD/WB RD CPAKE NY 125161012
01 600025433 000079408
01 LD82LA81LD71LD50LD61AE1
6 06060602060100000000
5 of 5
Preview
FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700 088 NYSCEF SUPREME DOC. COURT NO. 1 OF THE STATE OF NEW YORK RECEIVED NYSCEF: 03/30/2021 v2-1(A81) COUNTY OF COLUMBIA ---------------------------------------- SUMMONS AND VERIFIED COMPLAINT CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD Index No. Date Filed: Plaintiff(s), The basis of the venue for trial designated is;defendant(s) resides AGAINST in COLUMBIA County. SUSAN MCAVOY Plaintiff's place of business is at:283 MOUNTAIN VIEW RD COPAKE ,NY 103 ADAMS RD 12516 COPAKE ,NY 125161012 . COLUMBIA County 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 Plaintiff s Attorney within 20 days after service of this summons, exclusive of the day of service, or if service of this summons is made by any means other than by personal delivery to you within the state, within 30 days after such service is complete. In case of vour failure to answer, judgment will be taken against you by default for the relief demanded in the complaint. Pa L rks, Es Attor ey for PlaintiÎf(s) Dated: 3/03/21 Law Offices of Paul L. Marks, P L.L.C. Newburgh, New York 299 N2 Plank Road - Suite 104 Newburgh, New York 12550 [845) 561-6917 VERIFIED-AFFIRMED COMPLAINT 1. Plaintiff(s) is.a NEW YORK corporation and is authorized to do -business in the State of New York 2. Uoon information and belief Defendant(s) resides in the within county at the address shown above. AS AND FOR A FIRST CAUSE OF ACTION - ACCOUNT STATED 3. Defendant(s) owe plaintiff(s) for medical and/or transportation services accepted upon an account stated as of 3/16/19 for a sum certain in the principal amount of $1,820.74 together with interest from 3/16/19 in the amount of $336.84 AS D FOR A,SECOND CAUSE OF ACTION - BREACH OF CONTRACT 4. Defendant(s owe plaintiff(s) for breach of contract to pay for medical and/or transportation services provided for and accepted by defendant(s) as of 3/16/19 for the sum certain of $1,820.74 together with interest from 3/16/19 in the. amount of $336.84 AS AND FOR A. THIRD CAUSE OF ACTION - UNJUST ENRICHMENT 5. Plaintiff(s) repeats, reiterates and realleges each and every allegation contained in paragraphs 1 through 4 herein with the same force and effect as if fully set forth at length herein. 6. By reason of the foregoing, Defendant(s) SUSAN MCAVOY have been unjustly enriched in the sum of $1,820.74 , which has been and still due and owing to the Plaintiff(s) for the benefits conferred u n them by the Plaintiff(s) and accepted and retained by these Defendan Îs). 7. Demand has been made for payment herein for the above causes of action, howevere Defendant(s) has refused to tender any payment on this account. WWRRRFORE, plaintiff(s) demands judgment against defendant(s) on each of the above causes of action in the amount of $2,157.58 together with interest from 3/03/21 plus costs and disbursements of this action. Dated: 3/03/21 L w Offi s of Paul L. Marks, P.L.L.C. Newburgh, New York 2 N. ank Road - Suite 104 Newburgh, -New York 12550 (845) 561-6917 This is an attempt to collect a debt and any information obtainea will be used for that purpose. FILED 3/30/2021 1 of 5 FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700 066 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021 v2.1(D82) CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD - AGAINST - SUSAN MCAVOY 103 ADAMS RD COPAKE ,NY 125161012 Principal Due - $1,820.74 Interest - $336.84 Cost Statute - $200 . 00 .by Service of Summons - $47.24 Fee for INDEX No. - $210.00 _____________ TOTAL DUE - $2,614.82 ========= 2 of 5 FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021 LAW OFFICES OF PAUL L. MARKS, P.L.L.C. 299 N PLANK RD STE 104 NEWBURGH, NY 12550 (845) 561-6917 02/17/21 CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD JOANN PILKINGTON PO BOX 327 FILE# 191373254 COPAKE, NY 12516 With your permission, the Law Offices of Paul L. Marks, P.L.L.C. will institute legal action on your behalf against the following account: ACCOUNT #/S NAME AND ADDRESS 0177 SUSAN MCAVOY $1,820.74 SERVICE DATE 103 ADAMS RD 03/16/19 COPAKE, NY 12516-1012 IT IS IMPORTANT THAT YOU: 1. Return this letter to our office and please indicate the correct balance. 2. Please DO NOT accept payments from the debtor, refer him to our office. 3. Mark your records to indicate that this account has been referred to the attorney. VERIFICATION STATE OF NEW YORK: COUNTY OF D/2Ó JOANN PILKINGTON being duly sworn, deposes and says: I am the /}(6/ of CLAUSSON RAUGHT COMMUNITY RESCUE SQUAD a corporation, one of the parties to the action: I have read the annexed Complaint, know the contents thereof and the same are true to my knowledge, except those matters therein which are stated to be alleged on information and belief, and as to those matters I believe true. My belief, as to those matters therein not stated upon knowledge, is based upon the following: books, papers records in my possession. worn to before me on o . ERIN F. CONKLIN NotaryPublic,StateOfNewY Reg.No.01CO6231048 Con 3 of 5 FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021 ATTORNEY CERTIFICATION I,PAUL L. MARKS, ESQ., HEREBY CERTIFY, under the penalty of perjury and as an officer of the Court I have no knowledge that.the substance of any factual submissions contained in this document is false. This Certification is based solely and exclusively upon information provided by the client, and upon the client's certification to the undersigned attorney that such information is not false, and is not made based upon by the undersigned attorney or anyone acting on behalf of said attorney. PLEASE TAKE FURTHER NOTICE, that this Certification is made by the attorney as an officer of the Court and is directly solely and exclusively to the Court in accordance with 22 NYCRR 202.16 (e) and is expressly not directed or extended to the opposing party herein. PLEASE TAKE FURTHER NOTICE that the opposing party may not and should not rely upon this Attorney Certification in assessing the truth or validity of the information contained in the annexed document. The credibility of this submission is no greater than the credibility of the client represented by the undersigned attorney and the opposing party should give this document no greater credence because itbears this Attorney Certification. Dated: P L L.MA S, ESQ, 4 of 5 FILED: COLUMBIA COUNTY CLERK 03/30/2021 12:56 PM INDEX NO. E012021016700 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/30/2021 CBHV (L)E(G)AL APPLICATION V2.0 Time: 16:24:41 ------ ********************* Date: 3/25/21 NJLG16 * SlM0NS PROCESSED * 6 Copy * SUPREK C0lRT * ********************* ACCOUNT INTEREST INTR MR SlM0NS CO CASE# PLAINTIFF(S) (LIST ALL (N SlM10NS) BALANCE FRM DATE DAYS RATE INTEREST __ _________ ___________-___-____ _____________________________ ------.___ -------- -- ______ __________ 01 191373254 CLAUSSON PAH1T CCM1UNITY RESCUE SQUAD 1,820.74 3/16/19 740 .00025 336.84 283 K)UNTAIN VIEW RD CDPAKE NY 12516 œLitiBIA TOTAL SlI+DNS INTEREST; 336.84 PLAINTIFF(S) CLASS:. A - AMBULANCE SERVICES OSTS BY STATUTE: 200.00 SERVICE 0F SlI†INS: 47,24 QUNTY INDEX NltiBER: 210,00 TOTAL SU‡DNS COSTS: 457.24 TOTAL OF ALL (DPANIONATED BALANCES: 1,820.74 TOTAL SlM10NS: 2 614.ÏÖ T CASE# DEFENDANT(S) DTE ENTD SlMES CITY SlMONS COUNTY 01 191373254 SUSAN MCAVOY 3/25/21 COLlNBIA H0Æ0AER: Y 103 AD/WB RD CPAKE NY 125161012 01 600025433 000079408 01 LD82LA81LD71LD50LD61AE1 6 06060602060100000000 5 of 5