Preview
FILED: PUTNAM COUNTY CLERK 06/01/2021 09:20 AM INDEX NO. 500786/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/01/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF PUTNAM
FAXTON ST. LUKES HEALTHCARE
PO BOX 4849
UTICA, NY 13504
SUMMONS
Plaintiff,
Index No.
Date Filed
THERESA ALVAREZ
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
attorneys within twenty days after service of this summûñs, exclusive of the
day of service, or thirtydays after service iscompleted summons
if this isnot 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 reliefdemanded in the complaint.
The basis of venue isthat the defeñdañt reside(s) in the County of PUTNAM.
Dated:
Brian S. Stroh
OVERTON, SSELL, D RR AND DONOVAN, LLP
Attorneys for the
19 Executive Park Dr.
CliftonPark, New York 12065
(518) 383-4876
FORPROCESSSERVERONLY
DEFENDANT 1: DEFENDANT 2:
THERESA ALVAREZ
51 Livingston Rd
CARMEL, NY 10512
NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
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FILED: PUTNAM COUNTY CLERK 06/01/2021 09:20 AM INDEX NO. 500786/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/01/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTYOF PUTNAM
FAXTON ST. LUKES HEALTHCARE
VERIFIED
COMPLAINT
Plaintiff,
Index No.
THERESA ALVAREZ
Defendant(s).
The plaintiffalleges:
1. The Plaintiff
isa domestic corporation authorized to establish and maintain a hospital to render
hospital and medical services.
2. Upon inferniation 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 forthabove, such
address being the address of the defendant last known to the plaintiff
and/or the address provided to the
plaintiffby the defendant at the time services were rendered.
3. From March 7, 2020 to March 7, 2020, the at
plaintiff, the express or implied request of the
defendant, rendered hospital and/or medical services to the defendant, or individuals for whom the
defendant isfinancially responsible.
4. Upon information and belief, the plaintiff
sent the defendant numerous billingstatements to the
address provided at the time services were rendered or the last known address and before the account
came to counsel's officefor collections. Additiana||y, counsel's office also sent written correspondence to
the defendant, at the lastknown address or the address provided to the and
plaintiff, before commencing
this lawsuit. Although due demand has been made, the defendant has failed to pay the fullamount due
for services rendered by the plaintiff.
5. The reasonable value and agreed price of such services that remains unpaid is$3,408.67.
WHEREFORE , theplaintiffdemands judgrñent against the defendant in thesum of $3,408.67
with interest from March 7,2020, plus the costs and disbursements of the action and for such other,
further or differentrelief as to this Court may deem just.
DATED:
Brian S. Str bI
OVERTON, , DOERR AND DONOVAN, 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.
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FILED: PUTNAM COUNTY CLERK 06/01/2021 09:20 AM INDEX NO. 500786/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/01/2021
SVC-H-3 (81)
SUPREME COURT OF THE STATE OF NEW YORK :
: ss. :
COUNTY OF PUTNAM
FAXTON ST.LUKES HEALTHCARE
PO BOX 4849
UTICA, NY 13504 Plaintiff,
VERIFICATION
THERESA ALVAREZ Defendant(s).
The undersigned, being duly sworn, deposes and says:
1. I am an officer or agent of the which
plaintiff, isa domestic corporation authorized to establish
and maintain a hospital to render hospital and medical services..
2. I have read the foregoing complaint and the same istrue to my knowledge, except those matters
alleged upon infarrñaticñ and belief,and as to those matters, I believe it tobe true.
3. The grounds of my belief as to allmatters not stated upon my knowledge are the plaintiff's
business records.
KATHY WENGF T
MANAGER PATIENT ACCOUNTING
Sworn to before me this
da ,20
ublic
------------ ' .'
, . ·.~::.. -
BRIAN S STROHL
Public,State of New Ybrk
Notary
No. 02ST6077153
Qualified inSaratoga County
Commission Expires July 08, 20
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