On August 19, 2021 a
Complaint,Petition
was filed
involving a dispute between
Malta Med Emergent Care,
and
Venus J Heflin,
for Commercial - Contract
in the District Court of Saratoga County.
Preview
FILED: SARATOGA COUNTY CLERK 08/19/2021 01:00 PM INDEX NO. EF20212488
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SARATOGA
MALTA MED EMERGENT CARE
PO BOX 5178
SARATOGA SPRINGS, NY 12866
SUMMONS
Plaintiff,
Index No.
Date Filed
VENUS J HEFLIN
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 plainüif'sattameys within twenty days after service of this summens, exclusive of the
day of service, or thirtydays afterservice iscompleted summons
if this 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 reliefdemanded in the complaint.
The basis of venue isthat the defendant reside(s) in the County of SARATOGA.
Brian S. Stroh s Esq.
OVERTON, US , DOERR AND DONOVAN, LLP
Attorneys for t e Plaintiff
19 Executive Park Dr.
CliftonPark, New York 12065
(518) 383-4876
FORPROCESS SERVERONLY
DEFENDANT 1: DEFENDANT 2:
VENUS J HEFLIN
PO ROY 9625
°
CM4on c 90b5
NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
1 of 3
FILED: SARATOGA COUNTY CLERK 08/19/2021 01:00 PM INDEX NO. EF20212488
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SARATOGA
MALTA MED EMERGENT CARE
VERIFIED
COMPLAINT
Plaintiff,
Index No.
VENUS J HEFLIN
Defendant(s).
The plaintif
f alleges:
1. The Plaintiffisa deniestic corporation authõrized to establish and maintain an emergent care
center and render medical services.
2. Upon infern at|on and belief,defendant resides, or the transacticñ took place in the COUNTY in
which thisaction was commenced and the defeñdañt res|des at the address set forthabove, such
address being the address of the defendant lastknown to the plaintiffand/or the address provided to the
plaintiff
by the defendant at the time services were rendered.
3. From June 24, 2020 to June 24, 2020, the plaintiff,at the express or implied request of the
defendant, rendered amergent medical services to the defêñdañt, or individuals for whom the defendant
is financiallyresponsible.
4. Upon information and belief, the plaintiff
sent the defêñdañt 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 office for co!!ectioñs. Additicñally, counsel's office also sent written correspondence to
the defendant, at the last known address or the address provided to the and
plaintiff, before cGninióñcing
this lawsuit. Although due demand has been made, the defendant has failedto pay the fullamount due
for services rendered by the plaintiff.
5. The reasonable value and agreed price of such services that remains unpaid is$3,127.22.
WHEREFORE , theplaintiffdernañds judgment againsi the defendant inthe surn of $3,127.22
with interest from June 24, 2020, plus the costs and disbursements of the action and for such other,
further or differentreliefas to this Court may deem just.
Brian S. Strohl, Esq.
OVERTON, USSELL, ERR AND DONOVAN, LLP
Attorneys fo
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: SARATOGA COUNTY CLERK 08/19/2021 01:00 PM INDEX NO. EF20212488
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/19/2021
SVC-H-3 (81)
SUPREME COURT OF THE STATE OF NEW YORK :
: ss. :
COUNTY OF SARATOGA
MALTA MED EMERGENT CARE
PO BOX 5178
SARATOGA SPRINGS, NY 12866 Plaintiff,
VERIFICATION
VENUS J HEFLIN Defendant(s).
The undersigned, being duly sworn, deposes and says:
1. I am an officeror agent of the which
plaintiff, isa domestic corporation authorized to estab!!sh
and maintain an araergéñt care center and render medical services..
2. I have read the foregaing complaiñt and the same istrue to my knavv|educ, except those matters
e!!eged upon information and belief, and as tothose matters, I believe itto be true.
3. The grounds of my belief as to allmatters not stated upon my khuvv|ed are the plaintiffs
business records.
...... ....._..__.
CREDIT & COLLECTION MANAGER
Sworn to before me this
Nota ublic
,- .-..--
BRIAN S STROHL
Notary Pubile, Stateof NewYork
No. 02ST6077153
QualifiedIn Saratoga County
Commission Expires July 08, 20
3 of 3
Document Filed Date
August 19, 2021
Case Filing Date
August 19, 2021
Category
Commercial - Contract
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FILED: SARATOGA COUNTY CLERK 08/19/2021 01:00 PM INDEX NO. EF20212488 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SARATOGA MALTA MED EMERGENT CARE PO BOX 5178 SARATOGA SPRINGS, NY 12866 SUMMONS Plaintiff, Index No. Date Filed VENUS J HEFLIN 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 plainüif'sattameys within twenty days after service of this summens, exclusive of the day of service, or thirtydays afterservice iscompleted summons if this 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 reliefdemanded in the complaint. The basis of venue isthat the defendant reside(s) in the County of SARATOGA. Brian S. Stroh s Esq. OVERTON, US , DOERR AND DONOVAN, LLP Attorneys for t e Plaintiff 19 Executive Park Dr. CliftonPark, New York 12065 (518) 383-4876 FORPROCESS SERVERONLY DEFENDANT 1: DEFENDANT 2: VENUS J HEFLIN PO ROY 9625 ° CM4on c 90b5 NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 of 3 FILED: SARATOGA COUNTY CLERK 08/19/2021 01:00 PM INDEX NO. EF20212488 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SARATOGA MALTA MED EMERGENT CARE VERIFIED COMPLAINT Plaintiff, Index No. VENUS J HEFLIN Defendant(s). The plaintif f alleges: 1. The Plaintiffisa deniestic corporation authõrized to establish and maintain an emergent care center and render medical services. 2. Upon infern at|on and belief,defendant resides, or the transacticñ took place in the COUNTY in which thisaction was commenced and the defeñdañt res|des at the address set forthabove, such address being the address of the defendant lastknown to the plaintiffand/or the address provided to the plaintiff by the defendant at the time services were rendered. 3. From June 24, 2020 to June 24, 2020, the plaintiff,at the express or implied request of the defendant, rendered amergent medical services to the defêñdañt, or individuals for whom the defendant is financiallyresponsible. 4. Upon information and belief, the plaintiff sent the defêñdañt 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 office for co!!ectioñs. Additicñally, counsel's office also sent written correspondence to the defendant, at the last known address or the address provided to the and plaintiff, before cGninióñcing this lawsuit. Although due demand has been made, the defendant has failedto pay the fullamount due for services rendered by the plaintiff. 5. The reasonable value and agreed price of such services that remains unpaid is$3,127.22. WHEREFORE , theplaintiffdernañds judgment againsi the defendant inthe surn of $3,127.22 with interest from June 24, 2020, plus the costs and disbursements of the action and for such other, further or differentreliefas to this Court may deem just. Brian S. Strohl, Esq. OVERTON, USSELL, ERR AND DONOVAN, LLP Attorneys fo 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: SARATOGA COUNTY CLERK 08/19/2021 01:00 PM INDEX NO. EF20212488 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/19/2021 SVC-H-3 (81) SUPREME COURT OF THE STATE OF NEW YORK : : ss. : COUNTY OF SARATOGA MALTA MED EMERGENT CARE PO BOX 5178 SARATOGA SPRINGS, NY 12866 Plaintiff, VERIFICATION VENUS J HEFLIN Defendant(s). The undersigned, being duly sworn, deposes and says: 1. I am an officeror agent of the which plaintiff, isa domestic corporation authorized to estab!!sh and maintain an araergéñt care center and render medical services.. 2. I have read the foregaing complaiñt and the same istrue to my knavv|educ, except those matters e!!eged upon information and belief, and as tothose matters, I believe itto be true. 3. The grounds of my belief as to allmatters not stated upon my khuvv|ed are the plaintiffs business records. ...... ....._..__. CREDIT & COLLECTION MANAGER Sworn to before me this Nota ublic ,- .-..-- BRIAN S STROHL Notary Pubile, Stateof NewYork No. 02ST6077153 QualifiedIn Saratoga County Commission Expires July 08, 20 3 of 3