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  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
  • PROFESSIONAL CREDIT MGMT INC. VS KAYLAN NORTON CV-DEBT MEDICAL EXPENSES document preview
						
                                

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ELECTRONICALLY FILED 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 - 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