Preview
FILED: YATES COUNTY CLERK 10/04/2021 12:27 PM INDEX NO. 2021-5259
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2021
STATE OF NEW YORK Ref. No: G00834
COURT COUNTY OF YATES
SUPREME
SCHUYLER HOSPITAL INC
220 STEUBEN STREET
MONTOUR FALLS, NY 14865
Plaintiff,
Plaintiff designates
Yates County as
the place of trial.
vs.
The basis of the venue is
the residential address of
Defendant(s).
THEODORE PIPE JR
MEGAN PIPE
466 HAYES ROAD
DUNDEE, NY 14837
SUMMONS
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, or, if the complaint is not served with this Summons, to serve a notice of appearance on the
Plaintiffs Attorney(s) within 20 days after service of this summons, exclusive of the date of service (or
within 30 days after the service is complete if this Summons is not personally delivered to you within
the State of New York); and in case of your failure to appear or answer, judgment will be taken
against you by default for the relief demanded herein.
Date: September 30, 2021
CÓ R mond, Esq.
Attorney for laintiff
PO Box 1540
88 E. Tioga Avenue, Suite 201
Corning, NY 14830
607-654-7816
TO: THEODORE PIPE JR
MEGAN PIPE
466 HAYES ROAD
DUNDEE, NY 14837
1 of 3
FILED: YATES COUNTY CLERK 10/04/2021 12:27 PM INDEX NO. 2021-5259
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2021
STATE OF NEW YORK
SUPREME COURT COUNTY OF YATES
SCHUYLER HOSPITAL INC
Plaintiff, COMPLAINT
Against
THEODORE PIPE JR
MEGAN PIPE
Defendant(s)
Now comes the Plaintiff, by and through its attorney, Chad R. Hammond, Esq., and states as follows:
1. Plaintiff is a not-for-profit corporation authorized and operating under the laws of the state of New
York.
2. Defendant(s), Theodore Pipe Jr & Megan Pipe are residents of the State of New York with a last
known address of 466 Hayes Road, Dundee, NY 14837.
3. From on or about July 27, 2016, the Plaintiff rendered to the Defendant(s), Theodore Pipe Jr &
Megan Pipe, or to a person(s) dependent upon the Defendant(s) for their support, certain medical
services having a reasonable value of Twelve Thousand Two Hundred Two And 92/100 Dollars
($12,202.92), itemized statements of which are hereto annexed as Exhibit A.
4. Defendant(s), Theodore Pipe Jr & Megan Pipe, have not made any payments or offered a
payment plan, although duly demanded.
5. As such, Defendant(s), Theodore Pipe Jr & Megan Pipe, owe to Plaintiff the principal amount of
Twelve Thousand Two Hundred Two And 92/100 Dollars ($12,202.92), and interest in the amount
of Two Thousand Eight Hundred Four And 20/100 Dollars ($2,804.20).
6. Therefore, the Plaintiff demands judgment against Defendant(s), Theodore Pipe Jr & Megan
Pipe, for the sum of Fifteen Thousand Seven And 12/100 Dollars ($15,007.12), with interest
accruing thereon from September 30, 2021, plus costs, disbursements and attorney fees incurred
hereon as provided under said credit application.
WHEREFORE, Plaintiff demands judgment against the Defendant(s), Theodore Pipe Jr & Megan
Pipe, jointly and severally as follows:
1. In the amount of Fifteen Thousand Seven And 12/100 Dollars ($15,007.12);
2. Plus, cost, disbursements, interest and attorney fees;
3. Any and all additional relief the court deems just and proper in.
Dated: September 30, 2021 /
By:
Ch R. mond, Esq.
Attorney for intiff
PO Box 1540, 88 E. Tioga Avenue
Corning, NY 14830
607-654-7816
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FILED: YATES COUNTY CLERK 10/04/2021 12:27 PM INDEX NO. 2021-5259
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2021
SCHUYLER HOSPITAL INC
Plaintiff,
vs. VERIFICATION
THEODORE PIPE, JR.
MEGAN PIPE
Defendant(s)
STATE OF NEW YORK:
COUNTY OF SCHUYLER: ss
I, ALAIN SERGILE, being duly sworn, states that he is a representative of the plaintiff in this action and
that the foregoing complaint is true to his own knowledge, except as to matters therein stated to be
alleged on information and belief and as to those matters, he believes them to be true.
chuyler Hospital Inc.-Director of Revenue
Si n d and sworn t before me this
day of (gg , 2021
. . . . . .
MELISSA JEAN NORTON
Notary Public - State of New York
NO. 01N06275004
Qualified in Schuyler C
Pubhc unty
Notary My Commission Expires
3 of 3
Preview
FILED: YATES COUNTY CLERK 10/04/2021 12:27 PM INDEX NO. 2021-5259 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2021 STATE OF NEW YORK Ref. No: G00834 COURT COUNTY OF YATES SUPREME SCHUYLER HOSPITAL INC 220 STEUBEN STREET MONTOUR FALLS, NY 14865 Plaintiff, Plaintiff designates Yates County as the place of trial. vs. The basis of the venue is the residential address of Defendant(s). THEODORE PIPE JR MEGAN PIPE 466 HAYES ROAD DUNDEE, NY 14837 SUMMONS 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, or, if the complaint is not served with this Summons, to serve a notice of appearance on the Plaintiffs Attorney(s) within 20 days after service of this summons, exclusive of the date of service (or within 30 days after the service is complete if this Summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein. Date: September 30, 2021 CÓ R mond, Esq. Attorney for laintiff PO Box 1540 88 E. Tioga Avenue, Suite 201 Corning, NY 14830 607-654-7816 TO: THEODORE PIPE JR MEGAN PIPE 466 HAYES ROAD DUNDEE, NY 14837 1 of 3 FILED: YATES COUNTY CLERK 10/04/2021 12:27 PM INDEX NO. 2021-5259 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2021 STATE OF NEW YORK SUPREME COURT COUNTY OF YATES SCHUYLER HOSPITAL INC Plaintiff, COMPLAINT Against THEODORE PIPE JR MEGAN PIPE Defendant(s) Now comes the Plaintiff, by and through its attorney, Chad R. Hammond, Esq., and states as follows: 1. Plaintiff is a not-for-profit corporation authorized and operating under the laws of the state of New York. 2. Defendant(s), Theodore Pipe Jr & Megan Pipe are residents of the State of New York with a last known address of 466 Hayes Road, Dundee, NY 14837. 3. From on or about July 27, 2016, the Plaintiff rendered to the Defendant(s), Theodore Pipe Jr & Megan Pipe, or to a person(s) dependent upon the Defendant(s) for their support, certain medical services having a reasonable value of Twelve Thousand Two Hundred Two And 92/100 Dollars ($12,202.92), itemized statements of which are hereto annexed as Exhibit A. 4. Defendant(s), Theodore Pipe Jr & Megan Pipe, have not made any payments or offered a payment plan, although duly demanded. 5. As such, Defendant(s), Theodore Pipe Jr & Megan Pipe, owe to Plaintiff the principal amount of Twelve Thousand Two Hundred Two And 92/100 Dollars ($12,202.92), and interest in the amount of Two Thousand Eight Hundred Four And 20/100 Dollars ($2,804.20). 6. Therefore, the Plaintiff demands judgment against Defendant(s), Theodore Pipe Jr & Megan Pipe, for the sum of Fifteen Thousand Seven And 12/100 Dollars ($15,007.12), with interest accruing thereon from September 30, 2021, plus costs, disbursements and attorney fees incurred hereon as provided under said credit application. WHEREFORE, Plaintiff demands judgment against the Defendant(s), Theodore Pipe Jr & Megan Pipe, jointly and severally as follows: 1. In the amount of Fifteen Thousand Seven And 12/100 Dollars ($15,007.12); 2. Plus, cost, disbursements, interest and attorney fees; 3. Any and all additional relief the court deems just and proper in. Dated: September 30, 2021 / By: Ch R. mond, Esq. Attorney for intiff PO Box 1540, 88 E. Tioga Avenue Corning, NY 14830 607-654-7816 2 of 3 FILED: YATES COUNTY CLERK 10/04/2021 12:27 PM INDEX NO. 2021-5259 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/04/2021 SCHUYLER HOSPITAL INC Plaintiff, vs. VERIFICATION THEODORE PIPE, JR. MEGAN PIPE Defendant(s) STATE OF NEW YORK: COUNTY OF SCHUYLER: ss I, ALAIN SERGILE, being duly sworn, states that he is a representative of the plaintiff in this action and that the foregoing complaint is true to his own knowledge, except as to matters therein stated to be alleged on information and belief and as to those matters, he believes them to be true. chuyler Hospital Inc.-Director of Revenue Si n d and sworn t before me this day of (gg , 2021 . . . . . . MELISSA JEAN NORTON Notary Public - State of New York NO. 01N06275004 Qualified in Schuyler C Pubhc unty Notary My Commission Expires 3 of 3