Preview
FILED: FULTON COUNTY CLERK 09/14/2021 03:28 PM INDEX NO. EF2021-09363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/14/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF FULTON
NATHAN LITTAUER HOSPlTAL
99 EAST STATE ST
GLOVERSVILLE, NY 12078
SUMMONS
Plaintiff,
Index No.
Date Filed
JOANNE RUDD
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 plaintiffs attorneys within twenty days after service of this summons, exclusive of the
day of service, or thirty days after service is completed if this summons is not personally delivered to you
within the State of New York. Upon your failure to answer, a judgrñeñt will be entered against you by
default for the relief demanded in the complaint.
The basis of venue is that the defendant reside(s) in the County of FULTON.
Brian S. Stro I, Esq.
OVERTON, USSELL, ERR AND DONOVAN, LLP
Attorneys fo the Plain
19 Executive .
Clifton Park, New York 12065
(518) 383-4876
FORPROCESS SERVERONLY
DEFENDANT 1: DEFENDANT 2:
JOANNE RUDD
112 W PROSPECT ST
NORTHVILLE, NY 12134
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: FULTON COUNTY CLERK 09/14/2021 03:28 PM INDEX NO. EF2021-09363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/14/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF FULTON
NATHAN LITTAUER HOSPITAL
VERIFIED
COMPLAINT
Plaintiff,
Index No.
JOANNE RUDD
Defendant(s).
The plaintiff alleges:
1. The Plaintiff is a domestic corporation authorized to establish and maintain a hospital to render
hospital and medical services.
2. Upon information 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 forth above, such
address being the address of the defendant last known to the plaintiff and/or the address provided to the
plaintiff by the defendant at the time services were rendered.
3. From November 24, 2015 to November 25, 2015, the plaintiff, at the express or implied request
of the defendant, rendered hospital and/or madimi services to the defendant, or individuals for whom the
defendant is financially respansible.
4. Upon information and belief, the plaintiff sent the defendant numerous billing statements 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 collections. Additionally, counsel's office also sent written correspondence to
the defendant, at the last known address or the address pisvided to the plaintiff, and before commencing
this lawsuit. Although due demand has been made, the defendant has failed to pay the full amount due
for services rendered by the plaintiff.
5. The reasonable value and agreed price of such services that remains unpaid is $14,502.51.
WHEREFORE , the plaintiff demands judgment against the defendant in the sum of $14,502.51
with interest from NGvember 25, 2015, plus the costs and disbursements of the action and for such other,
further or different relief as to this Court may deem just.
DATED:
USf h Brian S. S o I, Esq.
OVERTON, L, 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: FULTON COUNTY CLERK 09/14/2021 03:28 PM INDEX NO. EF2021-09363
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/14/2021
SVC-H-3 (81)
SUPREME COURT OF THE STATE OF NEW YORK :
: ss. :
COUNTY OF FULTON
NATHAN LITTAUER HOSPITAL
99 EAST STATE ST
GLOVERSVILLE, NY 12078 Plaintiff,
VERIFICATION
JOANNE RUDD Defendant(s).
__
The undersigned, being duly sworn, deposes and says:
1. I am an officer or agent of the plaintiff, which is a 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 is true to my knowledge, except those matters
alleged upon information and belief, and as to those matters, I believe it to be true.
3. The grounds of my belief as to all matters not stated upon my knowledge are the plaintiff's
business records.
SUSAN SALA
MANAGER PAT NT FNCL SERVICES
Sworn to before me this
day of ,20 1l
Notary Public
TRICIA A. MOSHER
NOTARY PUBLIC-STATE OF NEW YORK
No. OlMO6229864
Qualified in Fulton County
My Commission Expires October 25, 20
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