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17501 BISCAYNE BOULEVARD, SUITE 420, AVENTURA, FL 33160

www.solnicklaw.com

Phone: 786-629-6530

Fax: 786-472-5670

May 28, 2020

VIA CERTIFIED MAIL

RETURN RECEIPT REQUESTED

Dr. Peter Rouvelas

Peter Rouvelas M.D. P.C.

8115 7th Avenue

Brooklyn, NY 11228

RE: Simplified Imaging Solutions v. Peter Rouvelas M.D. P.C. 

Dear Dr. Rouvelas:

I am the legal representative of Simplified Imaging Solutions (SIS). Please accept this 

as a revised letter as a demand for payment according to the attached contract.

On February 18, 2018, SIS and your practice entered into the attached contract. The 

contract required you to perform no less than 350 tests annually and/or pay a monetary 

equivalent. 

Our records indicate that you completed 127 tests between February 2018 and January 

2019; 196 tests between February 2019 and January 2020; and 34 tests between February 2020 

and today. Based upon communications with you, it is apparent that even prior to Covid-19 that 

you did not intend to complete any additional testing for the 2020-2021 year, and thereby have 

anticipatory breached the contract. This has resulted in a shortage of 693 tests. 

As a result, your practice owes SIS the monetary equivalent of $151,767.00 pursuant to 

the contract terms. My client is providing you 10 days to cure in accordance with the contract. 

Accordingly, pursuant to Article VI of the Agreement, SIS respectfully requests payment in the 

amount of $151,767.00, plus attorneys’ fees and costs. 

My client requests that the requested amount be paid within 10 days and payable to 

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Solnick Law P.A. Trust Account. If my client’s demands are unmet, I have been instructed to 

take any and all legal measures necessary to recover the monies it is entitled to pursuant to the 

contract, which requires the payment of legal fees and costs.

Since this will be a costly procedure for you, I would suggest you call me to discuss a 

resolution without resorting to such procedures. We therefore trust this will not be necessary, and 

that $151,767.00 will be paid within 10 days. Should we not hear from you within the 10 days, 

we will have no other option than to proceed by pursuing all available legal remedies in the State 

of Florida.

Should you wish to discuss the matter further, I may be reached at the number listed above.

Cordially,

/s/ Peter J. Solnick

Peter J. Solnick, Esq.

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