Case 2:21-cv-05355-FLA-E Document 1-4 Filed 07/01/21 Page 1 of 21 Page ID #:23
`Case 2:21-cv-05355-FLA—E Document 1-4 Filed 07/01/21 Page 1 of 21 Page ID #:23
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`EXHIBIT A‐4 
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`EXHIBIT A-4
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`twit
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`apitp.rdtp4§EftWet3.945rtstlaylledgst/ME)46 • 1.,tev2AilVarri R. Carter, Executive Officer/Clerk of Court, by R. Clifton Deputy Clerk
`1
`Case 2:21-cv-05355-FLA-E Document 1-4 Filed 07/01/21 Page 2 of 21 Page ID #:24
`Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Monica Bachner
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`Crystal Hayes Hill, 217201
`LAW Offices of Crystal Hayes Hill
`444 W. Ocean Blvd., Ste 800
`Long Beach, CA 90802
`(562) 444-5979
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`Attorney for Plaintiff, SILVER PEAKS, LLC.
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`SUPERIOR COURT OF ME STATE OF CALIFORNIA
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`FOR THE -COUNTY OF LOS ANGELES
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`2.8
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`))
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`Plaintiff,
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`In re:
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`SILVER PEAKS, LLC;
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`) COMPLAINT FOR DA_MAGES FOR
`)
`vs.
`)
`CAREMORE. HEALTH PLAN; COUNTRY)
`VILLA B.ELMONT HEIGHTS
`)
`HEALTHCARE CENTER (AKA BELMONT)
`liEIG.IITS HEALTHCARE: CENTER, LLCM
`ROCKPORT HEALTHCARE SUPPORT )
`SERVICES LLC.; DOES 1-10.
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`Case No.: 21STV19894
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`(1) FRAUD
`(2) BREACH OF CONTRACTS
`(3) ACCOUNT STATED
`(4) QUANTUM MERUIT
`(5) UNJUST ENRICHMENT
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`Defendant
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`Plaintiff, Silver Peaks, LLC hereby demands a trial on each and every action alleged and
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`item of damage prayed for herein. Plaintiff Silver Peaks, LLC. ("Plaintiff' or "Silver Peaks")
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`alleges as follows:
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`PARTIES
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`1. At all times herein mentioned, Plaintiff, SILVER PEAKS, LLC was. and is .a limited.
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`liability corporation doing business in the State of California and was and no.w is: a duly licensed,
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`California. based home care organization which provides non-medical services to patients that
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`reside in their own. home or that live in an elderly care facility. One of the non-medical services
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`provided by Plaintiff is. sitter services.
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`/II
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`COMPLAINT F04 DAMAGES
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`1
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`CASE'NO.:
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`

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`Lawyaoi Pa kage ID: d449dfe6-fd88-4513-8609-d0a77720bd46
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`Z. Plaintiff is. informed and believes and based thereon alleges that Defendant
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`CAREMORE HEALTH PLAN was; and is, at all relevant times mentioned herein, a California
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`Public entity doing business.in California. CAREMORE HEALTH PLAN herein after referred
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`to as "Care.More." CareMore is a medical. group health plan, care delivery system. and insurer
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`• thgt works with a subscriber member's insurance plan to deliver needed care to subscribing:
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`members.
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`1. Plaintiffia informed and believes and based on thereon alleges that COUNTRY
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`VILLA BELMONT HEIGHTS HEALTHCARE CENTER (AKA BELMONT HEIGHTS
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`HEALTHCARE CENTER, LLC.) was, at all relevant times mention herein, a California Public
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`entity doing business as a care facility in California with its principal Place of business located at.
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`1730 Grand Ave. #2011 Long Beach, CA 90804. COUNTRY VILLA 'BELMONT HEIGHTS
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`HEALTHCARE CENTER hereinafter referred to as "Country Villa. Belmont."
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`4. Plaintiff is informed and believes and based thereon alleges that Defendant
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`ROCKPORT HEALTHCARE SUPPORT SERVICES, LLC. was, and is, at all relevant times
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`mentioned herein, a California Public entity doing business in California. ROCKPORT
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`HEALTHCARE SUPPORT SERVICES, LLC herein after is referred to as "Rockport".
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`5. The true names and capacities, whether individual, corporate, associate, or otherwise
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`•of Defendants named herein as DOES 1 through 10 are unknown to Plaintiff who therefore sues
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`said Defendants by such fictitious names. Plaintiff is informed and believes and based thereon
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`alleges that Defendants and DOES 1 through 10, and each of them, are legally responsible to
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`Plaintiff for the relief sought herein and have liability to Plaintiff for all matters alleged herein.
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`6. Plaintiff is further informed and believes and based thereon alleges that all Defendants
`and Does 1 through 10, and each of them, are and were the agent, servant, employee principal,
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`COMPLAINT FOR DAMAGES
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`2
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`CASE NO.:
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`Lawyaw Pa ka0e ID: d449Ofe6-fd88-4513-8609-d0a77720bd46
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`master, employer, partner and/or joint venture of, and/or with, every other Defendant doing the
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`acts complained of herein, was acting within the scope of the relationship existing among
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`Defendants. Plaintiff will ask leave to amend this complaint-to show the true names and
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`capacities of the Defendant DOES when the same have been ascertained.
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`JURISDICTION AND VENUE
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`7. The Court has subject matter jurisdiction over this matter as California Superior
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`Courts are general jurisdiction courts. Plaintiff is suing for Fraud; Breach of Contracts; Account
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`Stated; Quantum Meruit; Unjust Enrichment
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`8. Los Angeles County is the proper venue for this action as both Plaintiff and
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`Defendant's primary place of business are in Los Angeles County and service was performed in
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`Los Angeles County.
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`FACTUAL ALLEGATIONS
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`9. Plaintiff is informed and believes and based on thereon alleges that on or around
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`March, 2 2020, Defendants CareMore and Country Villa Belmont entered into a Letter of
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`Agreement that provided that CareMore shall cover patient sitter services for the patient
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`Francisca Dewi herein after referred to as "Patient."
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`10. On or around March 2, 2020, CareMore contacted Silver Peaks requesting they
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`provide the sitter services agreed upon for the Patient under the Letter of Agreement.
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`11. Plaintiff rendered service in the form of sitter services for Patient from March 2, 2020
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`to March 18,2020. Plaintiff provided this service in Country Villa Belmont's facility located at
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`1730 Grand Ave. #2011 Long Beach, CA 90804.
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`COMPLAINT FOR DAMAGES
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`3
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`CASE NO.::
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`

`

`Lawyaw Pa
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`d449dfe64d88-4513-8609-d0a77720bd46
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`12. Plaintiff rendered service in the form of sitter services for Patient from January 17,
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`2020 to February 5, 2020. Plaintiff rendered this service in Country Villa Belmont's facility
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`located at 590 S Indian Hill Blvd. Country Villa Belmont, CA 91711.
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`2 3
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`13. In February of 2020, Plaintiff billed Country Villa Belmont by sending an invoice
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`6 showing the time and service rendered with the total amount due of $6,894.00. (See attached
`7 Invoice 50148 as Exhibit L)
`.8
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`14. In June of 2020, Plaintiff retained the Law Office of Crystal Hill to assiSt in receiving
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`payment for the sitter services rendered.
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`15. On July 13, 2020, Plaintiff through their attorney sent a letter to Country Villa
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`Belmont demanding payment for the sitter services rendered. (See attached Letter dated July 13,
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`2020 as Exhibit 2.)
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`16. On July 17, 2020, Plaintiff's attorney office called and left a voicemail for Lourdes
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`Rivera the business office manager at Country Villa Belmont. In that voicemail Plaintiffs
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`attorney office stated where they were calling from and whom they represented. A detailed
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`17. On July 23,2020, Plaintiffs attorney office called Country Villa Belmont and asked
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`to speak to Lourdes Rivera The receptionist stated that Ms. Rivera was working remotely from
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`home. Plaintiffs attorney office was then transferred to Ms. Rivera's assistant who stated that
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`"Jean" in the payroll department was handling the issue. Plaintiffs attorney office left a detailed
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`25 voicernAil with "Jean" regarding invoice 50148.
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`18. On July 29, 2020, Plaintiff's attorney office called to speak to Ms. Rivera; Plaintiffs
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`28 attorney office spoke to Ms. Rivera's secretary. Plaintiff's attorney office stated that this would
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`COMPLAINT FOR DAMAGES
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`4
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`CASE NO,.:
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`

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`Lawyaw Pa kage10: d449dte.64d88-4513-8609-d0a77720bd46
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`be the third message we leave for Ms. Rivera and if she does not reach out to us by end of day
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`we would be preparing the lawsuit.
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`19. On July 29,2020, at 11:12 a.m., Ms. Rivera called Plaintiffs attorney office stating
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`that Country Villa Behnont's Account Payable would be calling soon.
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`20. On July 29, 2020, at 11:31 axn., Ms. Rivera called Plaintiff's attorney office stating
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`that CareMore only authorize for one week of sitter services and that they should Only pay from
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`March 2, 2020 to March 8, 2020 for a total of $3,447.00. Ms. .'Rivers also stated that their Letter
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`of Agreement on states 16/hr. for sitter services. Ms. Rivera said that CareMore should have
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`canceled the services after March 8, 2020, but they didn't. Ms. Rivera also stated that CareMore
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`has not paid for any sitter services since Country Villa Belmont has not filed a claim for the
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`services rendered by Silver Peaks.
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`21. On August 31, 2020, Ms. Rivera called Plaintiffs,attorney office asking if we could
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`provide a Letter of Agreement that shows that Plaintiffs services were to last two weeks. She
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`stated that she is running all the information through Country Villa Belmont's parent company
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`Rockport.
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`22. Plaintiff is informed and believes that the Letter of Agreement signed by CareMore
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`and Country Villa Belmont and to which Silver Peaks is a beneficiary creates an obligation for
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`Defendants to pay invoice 500148. Plaintiff notified Defendants and sent multiple overdue
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`invoices. Defendant Country Villa Belmont has refused to pay.
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`*COMPLAINT FOR DAMAGES
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`5
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`CASE NO.:
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`LaWyaw Pa kage ID: d449dfe6-fd88-4513-8609-d0a77720bd46
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`•
`CAUSES OF ACTION
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`Fraud
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`23. Plaintiff incorporates by this reference the paragraphs alleged above as though fully
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`set forth here.
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`24. Plaintiff is informed .and believes and based on thereon alleges that CareMore,
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`Counny Villa Belmont and Rockport were aware of Plaintiff's hourly fee as listed. in
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`-Defendant's Letter of Agreement. Defendants induced Silver Peaks to perform these services to
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`Patient knowing that they would not execute their part of the agreement and pay .fOrthe service:
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`rendered.. CareMore, Country Villa Belmont and 'Rockport intentionally misrepresented that they
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`intended to •pay Silver Peaks for services 'rendered, in. part,. by soliciting sitter services based
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`upOn the Letter of Agreement.
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`25. When Silver Peaks began and provided the. service, they reasonably relied. on the fact
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`that they wouldbe paid when their services concluded per business customs, as hadbeen.dOne in
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`the past. Silver Peaks was not aware they were being induced to perform a service in which they
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`would not be compensated as the Letter of Agreement indicates Sitter services would be
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`reimbursed at 18/hr.
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`26. CareMore, Country Villa Belmont and Rockport fraudulently induce Silver. Peaks to
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`provide their services knowing that they had no intentions to pay any amount due to Silver Peaks
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`for the service provided. Thereby, they have deprived Silver Peaks of money due and owing to
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`them.
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`27. This is not the first time Rockport, the parent company of Country Villa Belmont
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`withheld funds due and owing to Silver Peaks. Rockport is well aware of the services performed
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`COMPLAINT FOR DAMAGES
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`.6.
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`CASE NO.
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`

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`Lawyaw Package ID: d449dfeerfd88-4513-8609-d0a77720bd46
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`by Silver Peaks and the value of such services. However, Rockport continues to withhold
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`payment and unjustly enriched itself fraudulently. For this aggrieved act, Silver Peaks is asking
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`for additional amount in punitive damages from Rockport in the amount of $100,000.00.
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`28. Plaintiff has had to devote a considerable amount of time tracking down Defendants
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`and demanding payment. Time spent doing this could have been used to garner more business
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`and Or retain existing clients. Plaintiff has three other claims against Rockport Facilities for
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`failure to pay. For this reason plaintiff is asking for punitive damages.
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`Breach of Contract
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`29. Plaintiff incorporates by this. reference the paragraphs. alleged above as. though fully
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`set' forth here.
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`30. Plaintiff performed by rendering services at the Country Villa Belmont facility to
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`Patient. CareMore agreed to pay by way of the Letter of Agreement CarelVlore and Country
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`Villa Belmont did not pay Plaintiff for services. CareMore and Country Villa Belmont breached
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`the contract
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`31. During the time that these services were being performed Country Villa Belmont
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`never, denied or stopped Plaintiff, Silver Peaks from sending their employees to perform their
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`duties as listed in the agreement.
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`32. Once the services were provided, Plaintiff as part of their normal business practice
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`sent invoice 50158 to Country Villa Belmont for payment. Country Villa Belmont has ignored
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`all attempts to collect Invoice, requests and demands were sent on March 2020 and July 13,
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`2020 for payment. Country Villa Belmont has not paid thus Country Villa Belmont has breached
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`contract with Plaintiff..
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`213
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`COMPLAINT POR DAMAGES
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`7
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`CASE NO.:
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`Lawyaw Pa kaga. d449dfe64d88-4513-8609-d0a77720bd46.
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`33. Country Villa Belmont has an outstanding balance of $6,894.00 for the service
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`rendered by Plaintiff. They accepted said services and thereby agreed to pay for services
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`rendered.
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`Breach of Contract as Third Party Beneficiary
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`34. Plaintiff incorporates by this reference the paragraphs alleged above as though fully
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`set forth here.
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`35. Plaintiff is informed and believes CareMore is a medical group, health plan and or
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`care delivery system and insurer that works with a subscriber member's insurance plan to deliver
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`needed care to subscriber members. Plaintiff is informed and believes that CareMore pays those
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`that are a part of the CareMore network that provide medical services to its subscriber members.
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`Plaintiff is informed and believes that Country Villa Belmont is apart of this network.
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`36. Silver Peaks provides and has provided services to CareMore's subscriber members.
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`As a vendor to a party of the contract, Plaintiff is a third-party beneficiary to the contract and to
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`the Letter of Agreement between CareMore and Country Villa Belmont.
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`37. Plaintiff is informed and believes that the facilities in which CareMore's subscriber
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`members are adinifted, typically submit claims on behalf of subscriber member. Plaintiff is
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`informed and believes that Country Villa Belmcint submitted the claim on behalf of Patient and
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`received payment from CareMore, but Rockport, County Villa Belmont's parent company, is
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`refusing to release funds to Plaintiff.
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`8. Plaintiff is an intended.third-party beneficiary of the contract. between CareMore and
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`Country Villa Belmont. Sitter services are a covered service under CareMore plan and
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`COMPLAINT FOR DAMAGES
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`8
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`CASE NO.:
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`Lawyaw Pa kage ID: d449dfe6-fd.88-4513-8609-d0a77720bd46
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`'CareMore has paid for such services in the past. Therefore, Plaintiff as the vendor of such
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`services is an intended third party beneficiary.
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`39. Defendants have breached its contract and duty to tbind party beneficiary by refusing
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`to pay Silver Peaks. Plaintiff is therefore suing Defendants for damages in the amount of
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`$6,894.00 plus interest, plus costs of suit and attorney's fees, totaling no less than $50,000.00
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`40. As a licensed vendor of a covered service, Defendants promised to pay Plaintiff for
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`the arranged care. The care was given and provided by Plaintiff. CareMore however did not pay.
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`Country Villa_Belmont also did not pay. Plaintiff is the intended. beneficiary of this contract and
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`as the aggrieved party, a benefit was conferred, but payment was not given.
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`Breach of Implied Contract
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`41. Plaintiff incorporates by this reference the paragraphs alleged above as though fully
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`set forth here.
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`42. In every work contract like the that one in which this case arises from there is a
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`business practice and a covenant of implied law exists that a contractor would be allowed to
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`perform work in a reasonable manner and in a reasonable efficient sequence. The present project
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`is no different. Plaintiff performed and services were rendered. However, the Defendants have
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`not executed payment for the services provided.
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`43. Plaintiff provided a service to Patient in Country Villa Belmont's facility in
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`exchange for payment. That payment was never received. This is a breach of the implied
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`agreement between the two parties.
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`44. Plaintiff and Defendants have a history of working together in similar implied
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`agreements. In previous agreements CareMore has contacted Silver Peaks in regards to sitter
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`CONLPLANT F04:DAIVIAGES
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`9
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`CASE NO,:
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`Lavvyaw Pa:kage ID: d449dfe64d88-4513-8609-d0a77720bd46
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`service required. Silver Peaks confirms availability and begins rendering service for CareMore
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`subscribing member at the facility in which they are located. Once service rendered is completed
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`Silver Peaks then sends an invoice to said facility in which the subscribing member was located.
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`The facility must then submit a claim to CareMore billing for the invoiced received by the
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`facility. Once CareMore, receives the claim they then send a check to either the facility or the
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`facility's parent company. Once those funds are received the facility or the facility's parent
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`company then pays Silver Peaks for 'the services rendered.
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`45. hi this case, Plaintiff believes that the Country Villa Belmont may have submitted a
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`claim and Rockport has received the funds from CareMore for the claim submitted. However,
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`Country Villa Belmont nor Rockport has paid Silver Peaks directly per business practice;
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`therefore Defendants have breached the implied contract.
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`Account Stated
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`46. Plaintiff incorporates by this reference the paragraphs 'alleged above as though fully
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`set forth here.
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`47. On or around March 2, 2020, Defendants'CareMore. and Country Villa Belmont
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`entered into an agreement stating that services would be provided for Patient. On or around
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`March 2, 2020, a CareMore case manager contacted Silver Peaks to perform the agreed upon
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`patient sitter services. Plaintiff performed sitter services from March 2, 2020 to March 18, 2020.
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`48. Plaintiff is infOrined. and believes that Patient was a. member subscriber to CareMore.
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`Therefore, the sitter services provided by Plaintiff were covered under CaMMore sem7icqs.
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`49. Plaintiff performed the services and Country Villa Belmont accepted the services
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`rendered from march 2,- 2020. to March 18, 2020.
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`COMPLAINT FOR DAMAGES
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`10
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`CASE NO.:
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`LaWyaw Pa kage ID: d449dfe6408-451341609-d0a77720bd46
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`50. Country Villa Belmont allowed Plaintiff into their facility to perform the service
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`rendered throughout the dates of March 2, 2020, to March 18, 2020 and thereby accepted
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`liability for payment for the services rendered.
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`51. Plaintiff billed for said services. Plaintiff provided invoice 50148 to Country Villa
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`Belmont on several occasions. Country Villa Belmont acknowledged receipt of services and
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`receipt of invoices. A true and correct copy of the invoice is attached hereto as Exhibit 1.
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`52. However, CareMore, Country Villa Belmont and Rockport have not paid the amount
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`owed to Plaintiff.
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`53. CareMore, Country Villa Belmont and Rockport still owe Plaintiff the total amount
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`of $6,894.00 for the service performed, for the dates of March 2, 2020, to March 18, 2020.
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`• Quantum Merl*
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`54. Plaintiff incorporates by this reference the paragraphs alleged above as though fully
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`set forth here.
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`55. From March 2, 2020, to March 18,2020, Plaintiff rendered sitter services to a Patient
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`at the request of the facility where she stayed. The services rendered were covered by
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`CareMore's health plan. and one in which Country Villa Belmont benefitted from as it was
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`performed in their facility.
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`56. The services were accepted and used by the CareMore and Country Villa Belmont.
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`Services rendered were valued at $6,894.00. CareMore and Country Villa Belmont were aware
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`services were being performed and were aware that Plaintiff expected to be paid for such
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`services.
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`COMPLAINT FOR DAMAGES.
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`11
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`CASE NO.:
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`Lawyaw Pa kage ID: d449dfe6-fd884513-8609-ci0a77720bd46
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`57. Plaintiff has not received any payment towards Defendant's past due balance of
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`$6,894.00.
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`58. The value of Plaintiffs service provided aligns with the custom charge for the service
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`rendered and thus, CareMore .and Country Villa Belmont were charged a reasonable price for the
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`service provided.
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`Unjust Enrichment
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`59. Plaintiff incoiporates by this reference the paragraphs alleged above as though fully
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`set forth here.
`
`60. CareMore and Country Villa Belmont were unjustly enriched by Plaintiff's
`
`performance in that it caused Defendants to receive a benefit that they would have otherwise not
`
`received.
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`61. CareMore and Country Villa Belmont received services valued at $6,894.00. that
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`they would have not received from Plaintiff. In addition, they received the customer goodwill
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`that comes with providing a needed service th patients in their facility.
`
`62. Plaintiff would have not performed the services if they knew that Defendants had no
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`intentions to pay.
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`63. CareMore and CoLuitry Villa Belmont have been unjustly enriched. They received a
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`service in the amount of $6,894.00.00 that they did not pay for. Thus, this has unjustly enriched
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`Country Villa Belmont and left Plaintiff with an unpaid invoice that they must try to receive fair
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`compensation for.
`
`/II
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`1 2 3 4 5 6 7 9
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`COMPLAINT FOR 'DAMAGES
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`12
`
`CASE NO.:
`
`

`

`LaVvyavti Pa kage ID: c1449dfe6-fd88-4513-8609-d0a77720bd46
`
`As a result of the forgoing, Plaintiff has been damaged in an amount of $6,894.00 plus
`
`interest, and attorney's fees in the amount of $36,000.00 from brining this action and in an
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`amount according to proof at trial.
`
`Plaintiff has thus far incurred $36,000.00 in Attorney's Fees and damages because of
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`Defendant's actions.
`
`WHEREFORE, Plaintiff prays judgment as to all Defendants as follows:
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`1. For judgment according to proof at trial of $6,894.00 plus interest;
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`2. For Attorney's Fees in the amount of no less than $50,000.00
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`3. Punitive damages against Rockport bathe amount of $100,000.00
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`3. For interest;
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`4. For Prompt Payment Act Assessments according to Proof;
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`5. For Cost of suit incurred herein;
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`6. For such other and further relief as this court may deem just and proper.
`
`05/2512021
`Dated:
`
`67.1 1/41/
`
`Crystal Hayes Hill, Esq.
`Attorney for Silver Peaks, LLC.,
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`2 3
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`5 5 7 8 9
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`2.8
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`comPLAWT FQ.R. DAMAGES..
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`13
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`'CASE NO.:
`
`

`

`•Lawyaw Pa kage d449dfe64d88-451a-8609-d0a77nObc146
`
`VERIFICATION
`STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
`I have read the foregoing, COMPLAINT FOR DAMAGES, and know its contents. I am a
`party in this action. The matters stated in the foregoing documents are true and of my own
`knowledge except as to those matters, which stated on information and belief, and as to those
`
`matters, I believe them to be true,
`I declare under penalty of perjury under the laws of the State of California that the
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`foregoing is true and correct.
`
`05/24/2021
`
`Dated:
`4 4/41.. e
`
`Amir Jordan Esmail, Silver Peaks. LLC,
`Managing Member
`
`2 3 4 5 6 7
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`9
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`IQ
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`1.1
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`12
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`13
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`14
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`15
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`18
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`19
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`2Q
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`24
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`25
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`26
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`27
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`28
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`COMPLAINT FOR DAMAGBS
`
`1 4
`
`CASE
`
`

`

`Lawyaw Package ID: d449dte6-fd88-4513-8609-clOa77720bd46
`
`

`

`LaWyaw Package ID: d449dfa6-fd8.8-4513-8609-d0a77720bd46
`
`Silver Peaks LLC
`21515 Hawthorne Blvd
`Suite 200
`Torrance, CA 90503
`1 (8551 876 - 1466
`
`Francisca Dewi
`
`DESCRIPTION
`Et 3/2/20 7:00pm - 3/3/20 7:00am Meier
`3/3/20 7:00am - 7:00pm josefina
`
`3/3/20 7:00PM - 3/4/20 7:00am Amer
`
`3/4/20
`
`7:00pM.10Sefina
`
`3/4/20 7:00pm -3/8/20 7:00am Alner
`
`3/5/20 7:00am - 7:00priljosefina
`
`3/5/20 7:00pm - 3/6/20 7:30am Etta
`
`3/6/20 7:30am - 7:00pm josefina
`
`3/6/20 7:00pm - 3/7/20 7:12am Elsa
`
`3/7/20 7:12am 7:00pm Lucina
`
`3/7/20 7:00pm - 3/8/20 7:00am Luvin-iinda
`
`3/8/20 7:00am - 7:00pm Luclria
`
`3/8/20 7:000M 318/20 7:00am Luviminda
`
`3/9/20 7:004M - 7:00pm Antonio
`
`3/9120 7:00pm 3/10/20 7:00am Luviminda
`
`3/10/20 7:00am - 7:90pm Josefina
`
`30.0/20 7:00pm - 3/11120 7:00e.M LuviMinda
`
`3/11/20 7:00am - 7:00Prnlbsefina
`
`3/11/20 7:00pm - 3/12/20 7:17am Elsa
`
`3/12/20 7:17arn - 7:00prn JOsefina
`
`3/12/20 7:00pm - 3/13/20 7:00am Joel
`
`3/13/20 7:00am'- 7:00pm josefina
`
`Client
`
`Devil, Francisca
`
`invoice No.
`50148
`Invoice Date
`03/18/2020
`Date Due
`04/17/2020
`From 03102(2020 to :03/18/Z020
`
`Pay online at
`httpsVipayments.cleareareonfine.com
`'Your payment code is 038-879-2P2
`
`QUANTITY
`
`RATE
`
`AMOUNT
`
`12 Firs
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`12 hrs
`
`18.00/hr
`
`$216.00
`
`12.5 hrs
`
`18.00/hr
`
`$225.00
`
`11.5 hrs
`
`18.00/hr
`
`$207.00
`
`12.2 hrs
`
`18.00/hr
`
`$218.60
`
`11.8 hrs
`
`18.00/hr
`
`$212.40
`
`11 hrs
`
`12 hit
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`3.8.00/hr
`
`$198.00
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`18.00/hr
`
`18.00/hr
`
`$216.00
`$216.00
`
`18.00/hr
`
`$216.00
`
`12./83 hi-s
`
`18.00/hr
`
`$221;99
`
`11.717 hrs
`
`18.00/hr
`
`$210.91
`
`12 hrs
`
`12 hm
`
`18.00/hr
`
`$216.00
`
`16.00/hr
`
`$216.00
`
`

`

`LawyaW Package ID: d449dfe6-fd88-4513-8609Lc10a77720bd46
`Invoice 50148 - page 2- Dawi, Francisca
`
`El 3/13/20 7:00pm -3/14(20 7100ani Elsa.
`fl 3/14/20 7:00am - 7:00pm Lucina
`O 3/14/20 7:00pm - 3/15/20 7:00am Elsa
`n. 3415/20 7:008m - 7:00prn i ina
`
`.13 3/15129 7:000r1 - 1:6/20 7:008M Elsa
`fl 3/16/70 7:00am - 7:00pm Jay-at:
`§3 3/16/20 7:00pm- 3/17/20 7:00am Luviminda
`8 3/17/20 7:00am - 7:00prri Jay-ar
`n 3/17/20 7:00prn - 3/18/20 7:00am Luvimirmla
`113 31113(20 7:00am - 7:000m joSefina
`
`Aging Summary
`
`CURRENT 1 -30 DAYS
`
`31 - 60
`
`61 -90 91+
`
`TOTAL
`
`*0.00
`
`0.00
`,
`
`0.00
`
`6,894.00 0.00
`
`6,894.00
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`12 hrs
`
`18.00/hr
`
`$216.00
`
`18,00/hr
`
`$216.00
`
`18',00/hr
`
`$216.00
`
`18.00/hr
`
`$216.00
`
`18.00/nr
`
`S216,00
`
`12 .hrs
`
`18:00/hr
`
`$216.00
`
`12 hrs
`
`18.00/hr
`
`$216.00
`
`12 hrs
`
`18.00/hr
`
`$216.00
`
`12 hrs
`
`I8.00/hr
`
`$216.00
`
`12 his
`
`18.00/hr
`
`$216.00
`
`InvOice Total: $6,894.00
`
`Please tOcei• off this portion and return with your payment to the address below oi-Pay online htix.Wpaymenth.:efeareareanIine.com
`
`Froft'
`Francisca De*.
`
`mail to;
`Silver Peaks
`21515 Htwthoene alvtl
`Suite 200
`Torrance. CA 9.003
`
`Client
`
`Francisca Dewi
`5.0148 03/18/2020
`Amount Due on Tiii .Invoice:
`Amount tnelosetl:
`
`$:
`1
`
`

`

`Lavvyaw Package lb: d449dte64d88-4513.,8609-clOa777.20bd46
`
`

`

`I,awyaw.. Package ID: d449dfe6-fd8.8,4513-8609-d0a77720bd46.
`
`Crystal Hayes.Hill,Esq.
`Law Office of Crystal Hayes Hill
`444W. Ocean Blvd., Suite 800
`Long Beach, CA 90802
`(562) 111 5.979
`
`July 13, 2020
`
`Via Email and US Postal Mail
`Country Villa Belmont Heights Healthcare Center
`Attn: Calvin Warren; Lourdes Rivera
`1730 Grand Ave #2011
`Long Beach, CA 90804
`administrator@cvbelmontheightshc.com
`bom@cvbelmoutheightshc.com
`
`Re: Outstanding Balance/ Invoice No. 50148
`
`To Whom it May Concern:
`
`This office has been retained by Silver Peaks, LLC to pursue debt collection against your
`facility. This letter shall serve as formal notice that Silver Peaks, LLC intends to commence
`legal proceedings against you.
`
`Silver Peaks, LLC, is a licensed California based home care organization that provides home
`care services to individuals in skilled nursing facilities, rehabilitation facilities, hospitals and
`those residing at home. Home care services as defined under Health and Safety Code Section
`1796.12(n) is the assistance provided by a registered Home Care Aide to a client who, because of
`advanced age or physical or mental disability, cannot perform such services.
`
`Silver Peak's Home Care Aids (HCAs) provided services to a patient in your facility, Francisca.
`Dewi from March 2, 2020 through March 18, 2020. The cost for these services was $6,894.00.
`Your facility was billed for these services on March 18, 2020. (Invoice No. 50148 Dated
`03/18/2020 is attached.)
`
`Payment for these services has not been received. The outstanding balance of S6,894.00 is due
`and payable immediately. Silver Peaks has attempted numerous times to collect his debt and,
`although this debt has been acknowledged by your facility and corporate office, it has not been
`paid_ Your facility should have received payment from the Ca.reMore for this claim_ A portion
`of that payment is due to Silver Peaks. It has been more ti-orl 90 days since this invoice and claim
`was submitted_
`
`For this reason, this ietter shall serve as formal notice that Silver Peaks, LLC intends to
`commence legal proceedings against you. You may cure and or settle this matter to avoid a
`lawsuit by issuing a check payable to Silver Peaks, LLC, in the amount of $6,894.00 and send it
`to this office no later than August 12, 2020.
`
`

`

`Laviyaw Package ID: d44.9dfe0d884513-86097d0a77720bd46
`Crystal Hayes EMI, Esq.
`Law Office of Crystal Hayes Mil
`44W. Ocean I31vd., Suite 800
`Long Beach, CA 90802
`(562) 444-5979
`
`This is a business debt and as such a judgment against you may include the cost of filing an
`action, service of process, attorney's fees and interest on the outstanding balance per California
`Code of Civil Procedure 1033.
`
`Sincerely, b
`
`liayes
`Esq.
`Attorney for Silver Peaks, 1,_,1.e
`
`Encl.
`
`