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IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF FLORIDA

Case No. 

SIMPLIFIED IMAGING & DIAGNOSTICS, SIMPLIFIED 

IMAGING SOLUTIONS LLC d/b/a SIMPLIFIED 

IMAGING SOLUTIONS (SIS), 

A Florida Limited Liability Company,

Plaintiff,

v.

PETER ROUVELAS M.D. P.C.,

A New York Corporation

Defendant.

______________________________/

COMPLAINT

Plaintiff, SIMPLIFIED IMAGING & DIAGNOSTICS, SIMPLIFIED IMAGING 

SOLUTIONS LLC d/b/a SIMPLIFIED IMAGING SOLUTIONS (SIS) (SIS or Plaintiff), hereby 

files its complaint against Defendant, PETER ROUVELAS M.D. P.C. (Defendant), and alleges:

1. This is an action in excess of $75,000, exclusive of attorneys’ fees, court costs, and 

interest.

2. Plaintiff, SIMPLIFIED IMAGING & DIAGNOSTICS, SIMPLIFIED IMAGING 

SOLUTIONS LLC d/b/a SIMPLIFIED IMAGING SOLUTIONS (SIS) is a Florida Limited 

Liability Company, authorized to conduct business in the State of Florida. 

3. Avi Soffer and Armando Normandys are the two members of SIS. Each of 

Plaintiff’s Members are citizens and residents of the State of Florida. 

4. Defendant, PETER ROUVELAS M.D. P.C. is a New York Corporation. 

5. Subject matter jurisdiction is invoked pursuant to 28 U.S.C. § 1332, as all the 

parties are completely diverse in citizenship, and the amount in controversy exceeds $75,000.

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6. Venue is proper in this District by reason of 28 U.S.C. § 1391(b)(2), because all or 

a substantial part of the events giving rise to Plaintiff’s claims occurred in the Southern District of 

Florida. Venue is also proper given there is a valid forum selection clause incorporated into the 

contracts between the parties. 

7. All conditions precedent to this action have been performed or have been waived. 

COUNT I – BREACH OF CONTRACT

8. Plaintiff hereby incorporates paragraphs 1 through 7, as if they were fully set forth 

herein. 

9. On or about February 17, 2018, Plaintiff and Defendant entered into a Services 

Agreement. A copy of the agreement is attached as Exhibit A.

10. The agreement provided that Defendant was to perform no less than 350 Test 

Annually or pay the monetary equivalent. Ex A, Paragraph IV (A). 

11. Defendant breached the services agreement by failing to conduct 350 tests for the 

period between February 17, 2018 and February 16, 2019. 

12. Between February 17, 2019 and February 16, 2020, Defendant failed to conduct 

350 annually. 

13. Between February 17, 2020 and February 16, 2021, Defendant failed to conduct 

350 annually. Indeed, Defendant has anticipatory breached the contract. 

14. Plaintiff has suffered damages as a result of the breach. 

15. Defendant owes Plaintiff $151,767.00.

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WHEREFORE, Plaintiff, SIMPLIFIED IMAGING SOLUTIONS LLC demands judgment 

against Defendant, PETER ROUVELAS M.D. P.C. for actual and compensatory damages, 

interest, attorney’s fees, costs, and for such other relief as this Court deems just and proper.

June 17, 2020. Respectfully submitted,

SOLNICK LAW P.A. 

Attorney for Plaintiff

1634 Island Way

Weston, Florida 33326

17501 Biscayne Boulevard, Suite 420

Aventura, FL 33160

Tel: 786-629-6530

Email: pete@solnicklaw.com

/s/ Peter J. Solnick

By: ___________________________

Peter J. Solnick, Esq.

Fla. Bar. 670006

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