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Sapphire HC, LLC d/b/a Briarcliff Manor Center for Rehabilitation and Nursing v. Ro...

Docket 58192/2023, New York State, Westchester County, Supreme Court (Mar. 17, 2023)
Case TypeCommercial - Contract
TagsCommercial, Civil, Contract
Plaintiff - Petitioner Sapphire HC, LLC d/b/a Briarcliff Manor Center for Rehabilitation and Nursing
Defendant - Respondent Rosemarie Mastriano
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COMPLAINT

Document Sapphire HC, LLC d/b/a Briarcliff Manor Center for Rehabilitation and Nursing v. Rosemarie Mastriano, 58192/2023, 2 (N.Y. Sup. Ct., Westchester County Mar. 17, 2023)
Nursing Care (“Briarcliff Manor”, or “Plaintiff”), by its attorney, Law Office of Simon P. Wercberger, LLC, hereby complains of Defendant, Rosemarie Mastriano (“Mastriano”, or the “Defendant”), and upon information and belief, alleges as follows:
Following Defendant’s discharge from Briarcliff Manor, the Plaintiff sent invoices in the amount of $58,893.32 to the Defendant, requesting payment for the room, board and skilled nursing services it provided.
(Quantum Meruit) Plaintiff repeats each and every allegation contained in those paragraphs of the Complaint marked and numbered “1” through “13”, inclusive, with the same force and effect as though fully and at length set forth herein.
(Unjust Enrichment) Plaintiff repeats each and every allegation contained in those paragraphs of the Complaint marked and numbered “1” through “17”, inclusive, with the same force and effect as though fully and at length set forth herein.
(Account Stated) Plaintiff repeats each and every allegation contained in those paragraphs of the Complaint marked and numbered “1” through “20”, inclusive, with the same force and effect as though fully and at length set forth herein.
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SUMMONS

Document Sapphire HC, LLC d/b/a Briarcliff Manor Center for Rehabilitation and Nursing v. Rosemarie Mastriano, 58192/2023, 1 (N.Y. Sup. Ct., Westchester County Mar. 17, 2023)
The Basis of Venue is Plaintiff’s Address 620 Sleepy Hollow Rd.
Briarcliff Manor, NY 10510 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 Plaintiff's attorney within twenty (20) days after service of this Summons, exclusive of the date of service, (or within thirty (30) days after service is complete if the 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 in the complaint.
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