Complaint,Petition: Albany Medical Center Hospital v. Christopher Allard

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                                SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SCHENECTADY

 

ALBANY MEDICAL CENTER HOSPITAL
1275 BROADWAY
MENANDS, NY 12204

Plaintif, SUMMONS
Index No.
CHRISTOPHER ALLARD Date Filed
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 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 judgment 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 SCHENECTADY.

= AUIS 1.20)

     

OVERTON, R “DOERR AND DONOVAN, LLP
Attorneys for the Plaintiff

19 Executive Park Dr.

Clifton Park, New York 12065

(518) 383-4876

 

FOR PROCESS SERVER ONLY

DEFENDANT 1: DEFENDANT 2:

CHRISTOPHER ALLARD
3062 ALBANY ST

 

SCHENECTADY, NY 12304

NOTICE: WE ARE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SCHENECTADY

 

ALBANY MEDICAL CENTER HOSPITAL

VERIFIED
Plaintiff, COMPLAINT

Index No.

CHRISTOPHER ALLARD
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 June 13, 2020 to June 13, 2020, the plaintiff, at the express or implied request of the
defendant, rendered hospital and/or medical services to the defendant, or individuals for whom the
defendant is financially responsible.

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 provided 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 $1,975.07.

WHEREFORE , the plaintiff demands judgment against the defendant in the sum of $1,975.07
with interest from June 13, 2020, plus the costs and disbursements of the action and for such other,
further or different relief as to this Court may deem just.

i

Brian S. sik £31 hi, Es

Brians SUR ESa) RUSSELL, DOERR AND DONOVAN, LLP
we 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.SVC-H-3 (81)

SUPREME COURT OF THE STATE OF NEW YORK
ss. :

COUNTY OF SCHENECTADY

 

ALBANY MEDICAL CENTER HOSPITAL
1275 BROADWAY
MENANDS, NY 12204 Plaintiff,

VERIFICATION
CHRISTOPHER ALLARD Defendant(s).

 

The undersigned, being duly sworn, deposes and says:
1. 1am 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. | 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, | 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.
KAREN MEIN L

ASSISTANT VP OF FINANCE

Sworn to before me this
zm A et 20 Df

Notary Public

   

 

KEEN GRETCHEN WENDY
NOTARY PUBLIC, STATE OF NEW YORK
Registration No. 01KE6347057
Qualified in Schenectady County
Commission Expires September 06, 2024