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Faulkner County District Court in Conway - Small Claims & Civil Division
Jaime Hamerlinck - DIV 1 Clerk | Vickie Carter - DIV 2 Clerk
2024-Mar-04 21:38:04
CWCV-24-430
D09D02 : 9 Pages
IN THE DISTRICT COURT FOR FAULKNER COUNTY, ARKANSAS
CONWAY DIVISION
PROFESSIONAL CREDIT MANAGEMENT, INC. PLAINTIFF
Vs. No.
KAYLAN NORTON DEFENDANT
COMPLAINT-FORM
Plaintiff's Address: P.O. Box 4037, Jonesboro, AR 72403 (844) 522-5928.
Defendant's Address: 2695 Dave Ward Dr, Apt L3, Conway, Faulkner County, AR,
72034-6793.
Nature of Claim: Fees charged for medical services rendered by Baptist Health
Conway ("BHC"), BH Neurology OP Clinic ("BHNOC") LR Emergency Doctors Group
("LREDG") and BH Family Clinic Hillcrest ("BHFCH").
Nature and Amount of Relief Claimed: After application of all credits, the unpaid fee
for medical services provided to Defendant amounts to $943.85.
Date Claim Arose:
1. The last charge occurred on 09-06-22, BHC assigned its claim to Plaintiff on
01-25-24, a copy of which is attached hereto as Exhibit "A".
2. The last charge occurred on 11-09-22, BHC assigned its claim to Plaintiff on
01-25-24, a copy of which is attached hereto as Exhibit "A".
3. The last charge occurred on 01-11-23, BNOC assigned its claim to Plaintiff on
10-17-23, a copy of which is attached hereto as Exhibit "B".
4. The last charge occurred on 10-05-22, BNOC assigned its claim to Plaintiff on
10-17-23, a copy of which is attached hereto as Exhibit "B".
5. The last charge occurred on 02-06-22, LREDG assigned its claim to Plaintiff
on 10-17-23, a copy of which is attached hereto as Exhibit "C".
6. The last charge occurred on 02-08-22, LREDG assigned its claim to Plaintiff
on 10-17-23, a copy of which is attached hereto as Exhibit "D".
1
Factual Basis of Claim: Commencing on the dates referred to above, Defendant
received medical services from BHC, BHNOC, LREDG and BHFCH. The health
providers' claims for payment were assigned to Plaintiff and Plaintiff is the real
party in interest. Despite demand the claims remain unpaid.
MOTION AND BRIEF FOR ATTORNEY FEE
Plaintiff moves for the award of an attorney's fee pursuant to ARCP 54 and District
Court Rule 1(c).
Plaintiff's Attorney: Marshall & Singleton, PLC
P.O. Box 1955
Jonesboro, AR 72403
(870) 932-8137
(870) 933-8180 Fax
collections@marshallsingleton.net
By: \O—, MAR 01 2024
Kyle Singleton (AR Bar No. 2017164)
2
r
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Page 2
Master account number:
Guarantor one: KAYLAN NORTON, Guarantor two: PLAINTIFPS
Employment: ATHENAHEALTH, INC. EXHIBIT
Employment:
Client number:
AFFIDAVIT AS TO CORRECTNESS OF ACCOUNT
AND ASSIGNMENT OF ACCOUNT
Debtor(s) Obligated To Pay The Account: KAYLAN NORTON
Original Creditor: BAPTIST HEALTH CONWAY
CREDITOR AMOUNT INTEREST FEES TOTAL
BAPTIST HEALTH CONWAY 542.51 0.00 0.00 542.51
REF#: /PATIENT: NORTON,KAYLAN
LST CHG: 09-06-22,
BAPTIST HEALTH CONWAY 61.60 0.00 0.00 61.60
REF#: /PATIENT: NORTON,KAYLAN
LST CHG: 11-09-22, . -
TOTAL 604.11 0.00 0.00 604.11
t,
Original Creditor Reference No.: See above
Original Creditor Last Charge Date: See above
Original Creditor Last Payment Date: See above
Creditor To Whom The Account Is Owed: BAPTIST HEALTH CONWAY
Creditor Pursuing Collection Of The Account: Professional Credit Management, Inc. (PCM)
Patient or Person Receiving Goods or Services: See above
The undersigned, under oath, states: As ,(your title) I am authorized
to make the affidavit. I am familiar with the book and r cords of the origigl creditor; that the
information and statement of account(s) listed above is true and correct to the best of my knowledge,
information and belief; the services were necessary; that the fees charged for the services were customary
in the locale and reasonable in amount: that there are no credits and/or offsets due; the total amount
due, including interest, at the time this affidavit was executed is $604.11 and the applicable
interest rate is 0% per annum. Further, BAPTIST HEALTH CONWAY does hereby assign
and transfer to PCM all right, title and interest in the account(s), but, retains any liabilities related
to the account(s) for services rendered to the patient shown above in the amount of
$604.11. The debtor's account(s) has been assigned to PCM and PCM is granted full power to
collect, sue for, or settle said claim.
: BAPTIST • ALTH CONWAY
Nam
STATE OF ARKANSAS
COUNTY OF (RA.. -
SUBSCRIBED AND SWORN to before me, a Notary Public,this day of
207'1 .
DAWN GILSON
SAUNE COUNTY
NOTARY PUBLIC - ARKANSAS
My ComnlissiOn Expires July 07, 2029
NOTARY PUBLIC
Commission No. 12372548
THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
CONWAY, AR
PLAINTIFPS
EXHIBIT
Page 3
LAFFP
Page 2
Master account number:
Guarantor one: KAYLAN NORTON, Guarantor two:
Employment: ATHENAHEALTH, INC.
Employment:
Client number:
AFFIDAVIT AS TO CORRECTNESS OF ACCOUNT
AND ASSIGNMENT OF ACCOUNT
Debtor(s) Obligated To Pay The Account: KAYLAN NORTON
Original Creditor: BH NEUROLOGY OP CLINIC
CREDITOR AMOUNT INTEREST FEES TOTAL
BH NEUROLOGY OP CLINIC 152.17 0.00 0.00 152.17
REF#: /PATIENT: NORTON,KAYLAN
LST CHG: 01-11-23,
BH NEUROLOGY OP CLINIC 13.26 0.00 0.00 13.26
REF#: /PATIENT: NORTON,KAYLAN
LST CHG: 10-05-22, V
TOTAL 165.43 0.00 0.00 165.43
Original Creditor Reference No.: See above
Original Creditor Last Charge Date: See above
Original Creditor Last Payment Date: See above
Creditor To Whom The Account Is Owed: BH NEUROLOGY OP CLINIC
Creditor Pursuing Collection Of The Account: Professional Credit Management, Inc. (PCM)
Patient or Person Receiving Goods or Services: See above
The undersigned, under oath, states: As R - ev Cycle — Supervisor ,(your title) I am authorized
to make the affidavit. I am familiar with the books and records of the original creditor; that the
information and statement of account(s) listed above is true and correct to the best of my knowledge,
information and belief; the services were necessary; that the fees charged for the services were customary
in the locale and reasonable in amount: that there are no credits and/or offsets due; the total amount
due, including interest, at the time this affidavit was executed is $165.43 and the applicable
interest rate is 0% per annum. Further, BH NEUROLOGY OP CLINIC does hereby assign
and transfer to PCM all right, title and interest in the account(s), but, retains any liabilities related
to the account(s) for services rendered to the patient shown above in the amount of
$165.43. The debtor's account(s) has been assigned to PCM and PCM is granted full power to
collect, sue for, or settle said claim.
CRED TOR: BH UROLOGY OP CLINIC
,
Name
STATE OF ARKANSAS
COUNTY OF
SUBSCRIBED AND SWORN to before me, a Notary Public,this 174k. day of Ocki; ..t-
20 ,..1?‘
'NOTARY PUBLIC
THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
CONWAY, AR
PLAINTIFF'S
EXHIBIT
2--
Page 3
LAFFP
AFFIDAVIT AS TO CORRECTNESS OF ACCOUNT
AND ASSIGNMENT OF ACCOUNT
PLAINTIFF'S
Debtor(s) Obligated To Pay Acct: KAYLAN NORTON / IBIT
Original Creditor: LR EMERGENCY DOCTORS GROUP
Original Creditor Last Charge Date: 02-06-22 V
Original Creditor Last Payment Date:
Creditor To Whom The Account Is Ownri• LR EMERGENCY DOCTORS GROUP
Creditor Reference Number:
Creditor Pursuing Collection Of The Account: Professional Credit Management, Inc. (PCM)
Patient Or Person Receiving Goods or Services: NORTON,KAYLAN
The undersigned, under oath, states: As v, • - Supervisor,(your title) I am authorized
Cycie
to make this affidavit. I am familiar with the books and records of the original creditor; that the
information and statement of account(s) listed above is true and correct to the best of my knowledge,
information and belief; the services were necessary; that the fees charged for the services were
customary in the locale and reasonable in amount; that there are no credits and/or offsets due; the total
amount due, including interest, at the time this affidavit was executed is $149.31 and the applicable
interest rate is 0% per annum. Further, LR EMERGENCY DOCTORS GROUP does hereby assign and
transfer to PCM all right, title and interest in the account(s), but, retains any liabilities related to the
account(s) for services rendered to NORTON,KAYLAN in the amount of $149.31. The debtor's
account(s) has been assigned to PCM and PCM is granted full power to collect, sue for, or settle
claim.
ORIGIN L CREDITOR: LR EMERGENCY DOCTORS GROUP
By: P
NAME
LW
State of Arkansas
County of P,A4,11c.
SUBSCRIBED AND SWORN to before me, a Notary Public,this Cilik day of Ck+Avr
20 .
NOTARY PUBLIC
My commission expires:
THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
CONWAY, AR 08-30-22 09-12-23
NEWAFF
AFFIDAVIT AS TO CORRECTNESS OF ACCOUNT
AND ASSIGNMENT OF ACCOUNT
PLAINTIFF'S
Debtor(s) Obligated To Pay Acct: KAYLAN NORTON" EXHIBIT
Original Creditor: BH FAMILY CLINIC HILLCREST
Original Creditor Last Charge Date: 02-08-22 ./
Original Creditor Last Payment Date:
Creditor To Whom The Account Is Owed: BH FAMILY CLINIC HILLCREST
Creditor Reference Number:
Creditor Pursuing Collection Of The Account: Professional Credit Management, Inc. (PCM)
Patient Or Person Receiving Goods or Services: NORTON,KAYLAN
The undersigned, under oath, states: As —Rev Cycle Supervisor(your title) I am authorized
to make this affidavit. I am familiar with the books and records of the original creditor; that the
information and statement of account(s) listed above is true and correct to the best of my knowledge,
information and belief; the services were necessary; that the fees charged for the services were
customary in the locale and reasonable in amount; that there are no credits and/or offsets due; the total
amount due, including interest, at the time this affidavit was executed is $25.00 and the applicable
interest rate is 0% per annum. Further, BH FAMILY CLINIC HILLCREST does hereby assign and
transfer to PCM all right, title and interest in the account(s), but, retains any liabilities related to the
account(s) for services rendered to NORTON,KAYLAN in the amount of $25.00. The debtor's
account(s) has been assigned to PCM and PCM is granted full power to collect, sue for, or settle
claim.
ORIGIN L CREDITOR: BH FAMILY CLINIC HILLCREST
State of Arkansas
County of C',)
SUBSCRIBED AND SWORN to before me, a Notary Public,this 1.14 day of t')d4iya-
20 aa .
NOTARY PUBLIC
My commission expires:
THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
CONWAY, AR 08-30-22 09-12-23
NEWAFF
SERVICEMEMBERS CIVIL RELIEF ACT AFFIDAVIT
I swear or affirm that the Plaintiff, through inquiry to the Department of Defense Manpower
Datacenter or other means, is unable to determine whether or not the Defendant(s),
KAYLAN NORTON, is in military service as defined by
50 U.S.C.A. 501 et seq.
Is SSIONAL CREDIT MANAGEMENT, INC.
PROF
By: LO GOLQZ,2A11-141-1
NA E
STATE OF ARKANSAS
COUNTY OF CRAIGHEAD
SUBSCRIBED AND SWORN to before me, a Notary Public,this day of, .
20 ---2--' OFFICIAL SEAL - #12369787
MARTHA A. WILHOITE
NOTARY PUBLIC-STATE OF ARKANSAS
CRAIGHEAD COUNTY
MY COMMISSION EXPIRES: 04-01-29
THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
SERAAFF