IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

JESUS GABRIEL GELLA,

Plaintiff,

CASE NO.: __________

-vsDIVISION NO.: __________

HEALTHCARE REVENUE RECOVERY 

GROUP, LLC,

Defendant.

PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL 

Plaintiff alleges Healthcare Revenue Recovery Group, LLC (“HRRG”) violated the Florida 

Consumer Collection Practices Act § 559.55 et seq. (“FCCPA”), the Fair Debt Collection Practices 

Act 15 U.S.C. § 1692 et seq. (“FDCPA”), and the Telephone Consumer Protection Act 47 U.S.C. 

§ 227 (“TCPA”). 

PARTIES 

 

1. Plaintiff is a natural person and resident of Miami-Dade County, Florida. 

2. Defendant is a Florida limited liability company with its principal address at 1643 

North Harrison Parkway Building H, Suite 100, Sunrise, FL 33323. 

JURISDICTION AND VENUE 

3. Jurisdiction of this Court arises under the FCCPA and FDCPA. 

4. This Court has personal jurisdiction over Defendant because it conducts business in 

Florida making it foreseeable that Defendant would be haled into a Florida Court. See Burger King 

Corp. v. Rudzewicz, 471 U.S. 462, 474 (1985).

5. Venue is proper because Defendant transacts and conducts business here and the 

Filing # 154726987 E-Filed 08/04/2022 05:48:32 PM Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 1 of 19
facts giving rise to this lawsuit originated in Miami-Dade county, Florida. 

6. Plaintiff demands damages that exceed $30,000. 

FACTUAL ALLEGATIONS 

7. In the middle of 2021, Defendant began calling Plaintiff’s cell phone to collect an 

alleged past due medical debt. 

8. Upon information and belief, Defendant has not sent any written communication to 

Plaintiff in attempt to collect the debt. 

9. Since the initial communication about the debt, Defendant has not sent written notice 

with the following information as required by 15 U.S.C. § 1692g(a):

(1) the amount of the debt;

(2) the name of the creditor to whom the debt is owed;

(3) a statement that unless the consumer, within thirty days after 

receipt of the notice, disputes the validity of the debt, or any 

portion thereof, the debt will be assumed to be valid by the 

debt collector;

(4) a statement that if the consumer notifies the debt collector in 

writing within the thirty-day period that the debt, or any 

portion thereof, is disputed, the debt collector will obtain 

verification of the debt or a copy of a judgment against the 

consumer and a copy of such verification or judgment will be 

mailed to the consumer by the debt collector; and

(5) a statement that, upon the consumer’s written request within 

the thirty-day period, the debt collector will provide the 

consumer with the name and address of the original creditor, 

if different from the current creditor.

10. Defendant did not provide the above information to Plaintiff during their initial 

communication. 

11. Defendant has called Plaintiff’s cell phone from a multitude of different numbers to 

conceal its identity and attempt to collect the alleged debt. 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 2 of 19
12. For example, on March 14, 2022, Defendant called Plaintiff’s cell phone using phone 

number 865-269-2364.

13. Two days later, Defendant called Plaintiff’s cell phone again using phone number 

786-461-1512.

14. Defendant has called Plaintiff using an artificial or a pre-recorded voice saying the

following:

Hello, this is HRRG calling. Please return our call by calling 855-700-

4473 between the hours of 8:00 am and 5:00 pm and ask for Juan or 

speak to any person who answer your call.

15. Upon information and belief, Defendant did not have Plaintiff’s prior express 

consent to call his cell phone using an artificial or pre-recorded voice. 

16. Upon information and belief, if Defendant had prior express permission to call 

Plaintiff’s cell phone using an artificial or pre-recorded voice, Plaintiff revoked consent by expressly 

telling Defendant to cease all collection communication. 

17. Plaintiff has received hundreds of calls from Defendant using an artificial or prerecorded voice in attempt to collect the alleged debt. 

18. In March 2022, Plaintiff called Defendant to ask that all collection calls stop. 

19. During the call, Plaintiff asked Defendant’s employee to stop all collection 

communication. 

20. In response, Defendant’s debt collection employee told Plaintiff: “F_ck You will 

keep calling you Deadbeat.” 

21. The purpose of this offensive and abusive language was to coerce and intimidate 

Plaintiff to pay the alleged debt in hopes the illegal collection conduct would cease. 

22. Despite being asked to stop calling, Defendant continued its collection harassment

campaign. 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 3 of 19
23. Plaintiff again spoke with a collection employee of Defendant in hopes that the calls 

would stop.

24. In response, Defendant’s collection employee said: “F_ck your Mother” and then 

ended the call. 

25. Despite being asked to stop calling, Defendant continued its collection harassment

campaign. 

26. The interaction with Defendant’s employee caused Plaintiff stress and anxiety. 

27. After the call, Defendant ignored Plaintiff’s cease contact request and continued to 

call his cell phone with pre-recorded voice messages in attempt to collect the alleged debt. 

28. For example, on April 4, 2022, Defendant called Plaintiff’s cell phone in attempt to 

collect the alleged debt despite that Plaintiff asked for all collection communication to cease. 

COUNT I AS TO DEFENDANT’S VIOLATION OF THE 

FLORIDA CONSUMER COLLECTION PRACTICES ACT § 559.72(7) 

 

29. Plaintiff is a “consumer” as defined by Florida Statute § 559.55(8) because he is a 

natural person allegedly obligated to pay a debt for medical care. 

30. Defendant is a “person” as defined under the FCCPA because it attempted to collect 

a consumer debt from Plaintiff. 

31. Defendant attempted to collect a “consumer debt” from Plaintiff as defined by 

Florida Statute § 559.55(6) because the debt was allegedly incurred to pay for personal, family, or 

household purposes.

32. Defendant violated the FCCPA by willfully engaging in conduct which can reasonably 

be expected to abuse or harass Plaintiff. 

33. Defendant continued calling Plaintiff’s cell phone in attempt to collect a debt after 

being asked to stop calling. 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 4 of 19
34. During a collection call, Defendant’s employee also cursed at Plaintiff in attempt to 

collect the alleged debt. 

35. As a result of Defendant’s FCCPA violation, Plaintiff suffered actual damages, 

including but not limited to emotional distress, mental anguish, embarrassment, and frustration.

36. As a result of Defendant’s FCCPA violation, Plaintiff has also wasted time trying to 

stop Defendant’s illegal collection efforts. 

37. Because of the above violation of the FCCPA, Defendant is liable to Plaintiff for 

actual damages and statutory damages of $1,000.00 per named Defendant found liable, together 

with attorney’s fees and all costs of Plaintiff’s representation. 

COUNT II AS TO DEFENDANT’S VIOLATION OF THE 

FLORIDA CONSUMER COLLECTION PRACTICES ACT § 559.72(9) 

 

38. Plaintiff is a “consumer” as defined by Florida Statute § 559.55(8) because he is a 

natural person allegedly obligated to pay a debt for medical care. 

39. Defendant is a “person” as defined under the FCCPA because it attempted to collect 

a consumer debt from Plaintiff. 

40. Defendant attempted to collect a “consumer debt” from Plaintiff as defined by 

Florida Statute § 559.55(6) because the debt was allegedly incurred to pay for personal, family, or 

household purposes.

41. As described above, Defendant violated the FCCPA by using unfair and deceptive 

conduct when trying to collect the alleged debt from Plaintiff. 

42. Defendant had no legal right to use unfair and deceptive conduct when trying to 

collect the alleged debt from Plaintiff. 

43. Defendant knowingly continued calling Plaintiff’s cell phone using a pre-recorded 

voice in attempt to collect a debt after being asked to stop calling. 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 5 of 19
44. During a collection call, Defendant’s employee also cursed at Plaintiff in attempt to 

collect the alleged debt. 

45. As a result of Defendant’s FCCPA violation, Plaintiff suffered actual damages, 

including but not limited to emotional distress, mental anguish, embarrassment, and frustration.

46. As a result of Defendant’s FCCPA violation, Plaintiff has also wasted time trying to 

stop Defendant’s illegal collection efforts. 

47. Because of the above violation of the FCCPA, Defendant is liable to Plaintiff for 

actual damages and statutory damages of $1,000.00 per named Defendant found liable, together 

with attorney’s fees and all costs of Plaintiff’s representation. 

COUNT III AS TO DEFENDANT’S VIOLATION OF THE 

FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. § 1692d(2) 

48. Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3) because he is a natural 

person allegedly obligated to pay a debt for medical care. 

49. Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6) because it uses 

the United States mail in the business the principal purpose of which is the collection of debt owed 

or asserted to be owed or due another. 

50. Defendant is also a debt collector because its primary business purpose is the 

collection of debts. 

51. In attempt to collect the alleged debt, Defendant violated the FDCPA by using 

obscene and profane language the natural consequence of which was to abuse Plaintiff. 15 U.S.C. § 

1692(d)(2); Regulation F 1006.14(d). 

52. As a result of the FDCPA violation, Defendant has invaded Plaintiff’s statutory right 

to be free from illegal collection activity and caused him frustration and anxiety. 

53. As a result of Defendant’s FCCPA violation, Plaintiff has also wasted time trying to 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 6 of 19
stop Defendant’s illegal collection efforts. 

54. As a result of the above violation of the FDCPA, Defendant is liable to Plaintiff for 

actual damages, statutory damages up to $1,000.00, and attorney’s fees and all costs of Plaintiff’s 

representation. 15 U.S.C. § 1692k et seq.

COUNT IV AS TO DEFENDANT’S VIOLATION OF THE 

FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. § 1692f 

55. Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3) because he is a natural 

person allegedly obligated to pay a debt for medical care. 

56. Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6) because it uses 

the United States mail in the business the principal purpose of which is the collection of debt owed 

or asserted to be owed or due another. 

57. Defendant is also a debt collector because its primary business purpose is the 

collection of debts. 

58. In attempt to collect the alleged debt, Defendant engaged in unfair collection conduct 

by using obscene and profane language designed to abuse Plaintiff.

59. In attempt to collect the alleged debt, Defendant engaged in unfair collection conduct 

by refusing to stop all collection calls after Plaintiff expressly asked for the calls to stop. 

60. As a result of the FDCPA violation, Defendant has invaded Plaintiff’s statutory right 

to be free from illegal collection activity and caused him frustration and anxiety. 

61. As a result of Defendant’s FCCPA violation, Plaintiff has also wasted time trying to 

stop Defendant’s illegal collection efforts. 

62. As a result of the above violation of the FDCPA, Defendant is liable to Plaintiff for 

actual damages, statutory damages up to $1,000.00, and attorney’s fees and all costs of Plaintiff’s 

representation. 15 U.S.C. § 1692k et seq.

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 7 of 19
COUNT V AS TO DEFENDANT’S VIOLATION OF THE 

FAIR DEBT COLLECTION PRACTICES ACT 15 U.S.C. § 1692g 

63. Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3) because he is a natural 

person allegedly obligated to pay a debt for medical care. 

64. Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6) because it uses 

the United States mail in the business the principal purpose of which is the collection of debt owed 

or asserted to be owed or due another. 

65. Defendant is also a debt collector because its primary business purpose is the 

collection of debts. 

66. Under the FDCPA, a debt collector must provide written notice with the following 

information in the initial communication or within 5 days of the initial communication: 

(1) the amount of the debt;

(2) the name of the creditor to whom the debt is owed;

(3) a statement that unless the consumer, within thirty days after 

receipt of the notice, disputes the validity of the debt, or any 

portion thereof, the debt will be assumed to be valid by the 

debt collector;

(4) a statement that if the consumer notifies the debt collector in 

writing within the thirty-day period that the debt, or any 

portion thereof, is disputed, the debt collector will obtain 

verification of the debt or a copy of a judgment against the 

consumer and a copy of such verification or judgment will be 

mailed to the consumer by the debt collector; and

(5) a statement that, upon the consumer’s written request within 

the thirty-day period, the debt collector will provide the 

consumer with the name and address of the original creditor, 

if different from the current creditor.

67. Defendant violated the FDCPA because it did not provide Plaintiff the above 

information with the initial communication or within 5 days of the initial communication.

68. As a result of the FDCPA violation, Defendant has invaded Plaintiff’s statutory right 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 8 of 19
to be free from illegal collection activity and caused him frustration and anxiety. 

69. As a result of the FDCPA violation, Defendant has deprived Plaintiff from receiving 

critical information about the alleged debt, the debt collector, and his statutory rights to dispute the 

alleged debt. 

70. As a result of Defendant’s FDCPA violation, Plaintiff has wasted time trying to stop 

Defendant’s illegal collection efforts and learn of his statutory rights with respect to the alleged debt. 

71. As a result of Defendant’s FDCPA violation, Plaintiff did not know he had the right 

to dispute the alleged debt within (30) days. 

72. Had Plaintiff known he had that right, he would have disputed the debt within the 30 

days as permitted under the FDCPA. 

73. As a result of the above violation of the FDCPA, Defendant is liable to Plaintiff for 

actual damages, statutory damages up to $1,000.00, and attorney’s fees and all costs of Plaintiff’s 

representation. 15 U.S.C. § 1692k et seq.

COUNT VI AS TO DEFENDANT’S VIOLATION OF 

THE TELEPHONE CONSUMER PROTECTION ACT 47 U.S.C. § 227(b)(1)(B) 

74. Upon information and belief, Defendant willfully or knowingly violated the TCPA 

by calling Plaintiff’s cell phone number using an artificial or pre-recorded voice without the prior 

express consent of Plaintiff. 

75. Even if Defendant had prior express consent, Plaintiff revoked consent in March 

2022 when he expressly asked for all collection communications to cease. 

76. Defendant willfully or knowingly violated the TCPA by calling Plaintiff’s cell phone 

using an artificial or pre-recorded voice after consent was revoked. 

77. Defendant’s conduct constitutes violations of the TCPA 47 U.S.C. § 227(b)(1)(B), 

by making telephone calls to Plaintiff’s cellular telephone, which were initiated by an artificial or 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 9 of 19
prerecorded voice and not legally permitted under any provision to the aforementioned statute.

78. As a result of Defendant’s TCPA violation, Plaintiff is entitled to statutory damages 

of $500 per phone call using an artificial or pre-recorded voice. 47 U.S.C. § 227(b)(3).

79. As a result of Defendant’s knowing and willful violations of the TCPA, Plaintiff is 

entitled to treble statutory damages up to $1,500 per phone call that used an artificial or pre-recorded 

voice. 

RELIEF REQUESTED 

 

WHEREFORE, based on the above stated in this Complaint, Plaintiff has been the subject 

Defendant’s illegal debt collection conduct in violation of the FCCPA and FDCPA. Plaintiff 

respectfully requests this Honorable Court to enter judgment for the Plaintiff and for these forms of 

relief:

a) Actual damages.

b) Statutory damages under the FCCPA, FDCPA, and TCPA.

c) Punitive damages under the FCCPA.

d) Reasonable attorneys’ fees and costs under the FCCPA and FDCPA.

e) a judgment awarding injunctive and declaratory relief.

f) That the Court enter an order that Defendant and its agents, or anyone acting on 

their behalf, is immediately restrained from altering, deleting or destroying any documents or 

records; and

g) Any other relief that the Court may deem just and proper.

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 10 of 19
Plaintiff respectfully requests a trial by jury on all issues so triable. 

Respectfully Submitted, 

/s/ Darren R. Newhart

Darren R. Newhart, Esq. 

FL Bar No: 0115546

E-mail: darren@newhartlegal.com

NEWHART LEGAL, P.A.

14611 Southern Blvd. Suite 1351

Loxahatchee, FL 33470

Telephone: (561) 331-1806 

Facsimile: (561) 473-2946

/s/ Matthew D. Bavaro

Matthew D. Bavaro, Esq.. 

FL Bar No: 175821

E-mail: matthew@fight13.com

LOAN LAWYERS, LLC 

3201 Griffin Road #100

Fort Lauderdale, FL 33312

Telephone: (954) 523-4357 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 11 of 19
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JESUS GABRIEL GELLA VS HEALTHCARE REVENUE RECOVERY GROUP, LLC

Local Case Number: 2022-014599-CA-01 Filing Date: 08/04/2022

State Case Number: 132022CA014599000001 Judicial Section: CA08

Consolidated Case No.: N/A Case Type: Other Civil Complaint

Case Status: OPEN

 Parties

Total Of Parties: 2 

Party Description Party Name Attorney Information Other Attorney(S)

Plaintiff Gella, Jesus Gabriel B#:  (Bar Number)115546

N:  (Attorney Name)Newhart, Darren R

Defendant Healthcare Revenue Recovery Group, LLC

 Hearing Details Total Of Hearings: 0 

Hearing Date Hearing Time Hearing Code Description Hearing Location

 Dockets Total Of Dockets: 7 

Number Date Book/Page

Docket

Entry

Event

Type Comments

08/25/2022 20 Day

Summons

Issued

Service



7 08/25/2022 ESummons

20 Day

Issued

Event RE: INDEX # 5.

Parties: Healthcare Revenue Recovery Group LLC

6 08/25/2022 Receipt: Event RECEIPT#:3060082 AMT PAID:$10.00 NAME:NEWHART, DARREN R N/A

N/A, FL UNITED STATES COMMENT: ALLOCATION CODE QUANTITY UNIT

AMOUNT 3139-SUMMONS ISSUE FEE 1 $10.00 $10.00 TENDER

TYPE:EFILINGS TENDER AMT:$10.00 RECEIPT DATE:08/25/2022

REGISTER#:306 CASHIER:EFILINGUSER



5 08/15/2022 (M) 20 Day

(C)

Summons

(Sub)

Event 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 12 of 19
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4 08/10/2022 Receipt: Event RECEIPT#:3070143 AMT PAID:$401.00 NAME:NEWHART, DARREN R N/A

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Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 13 of 19
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Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 14 of 19
- 1 -

FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing

and service of pleadings or other documents as required by law. This form must be filed by the

plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant

to section 25.075, Florida Statutes. (See instructions for completion.)

I. CASE STYLE

IN THE CIRCUIT/COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Jesus Gella

Plaintiff Case #

Judge

vs.

Healthcare Recovery Group, LLC

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of

the claim is requested for data collection and clerical processing purposes only. The amount of the claim

shall not be used for any other purpose. 

 ☐ $8,000 or less

☐ $8,001 - $30,000

☐ $30,001- $50,000

☒ $50,001- $75,000

☐ $75,001 - $100,000

☐ over $100,000.00

III. TYPE OF CASE (If the case fits more than one type of case, select the most

definitive category.) If the most descriptive label is a subcategory (is indented under a broader

category), place an x on both the main category and subcategory lines.

Filing # 154726987 E-Filed 08/04/2022 05:48:32 PM Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 15 of 19
- 2 -

CIRCUIT CIVIL

☐ Condominium

☐ Contracts and indebtedness

☐ Eminent domain

☐ Auto negligence

☐ Negligence—other

☐ Business governance

☐ Business torts

☐ Environmental/Toxic tort

☐ Third party indemnification

☐ Construction defect

☐ Mass tort

☐ Negligent security

☐ Nursing home negligence

☐ Premises liability—commercial

☐ Premises liability—residential

☐ Products liability

 ☐ Real Property/Mortgage foreclosure

☐ Commercial foreclosure

☐ Homestead residential foreclosure

☐ Non-homestead residential foreclosure

☐ Other real property actions

☐Professional malpractice

☐ Malpractice—business

☐ Malpractice—medical

☐ Malpractice—other professional

☒ Other

☒ Antitrust/Trade regulation

☐ Business transactions

☐ Constitutional challenge—statute or ordinance

☐ Constitutional challenge—proposed amendment

☐ Corporate trusts

☐ Discrimination—employment or other

☐ Insurance claims

☐ Intellectual property

☐ Libel/Slander

☐ Shareholder derivative action

☐ Securities litigation

☐ Trade secrets

☐ Trust litigation

COUNTY CIVIL

☐ Small Claims up to $8,000

☐ Civil

☐ Real property/Mortgage foreclosure 

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 16 of 19
- 3 -

☐ Replevins

☐ Evictions

☐ Residential Evictions

☐ Non-residential Evictions

☐ Other civil (non-monetary)

COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the

Administrative Order. Yes ☐ No ☒

IV. REMEDIES SOUGHT (check all that apply):

☒ Monetary;

☒ Nonmonetary declaratory or injunctive relief;

☐ Punitive

V. NUMBER OF CAUSES OF ACTION: [ ]

(Specify)

3

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

☐ yes

☒ no

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

☒ no

☐ yes If “yes,” list all related cases by name, case number, and court.

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

☒ yes

☐ no

IX. DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE?

☐ yes

☒ no

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of

my knowledge and belief, and that I have read and will comply with the requirements of

Florida Rule of Judicial Administration 2.425.

Signature: s/ Darren R. Newhart Fla. Bar # 115546

Attorney or party (Bar # if attorney)

Darren R. Newhart 08/04/2022

(type or print name) Date

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 17 of 19
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

__________________________________________________________________________ 

__________________________________________________________________________ 

 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

DIVISION 

 CIVIL 

 DISTRICTS 

 OTHER 

SUMMONS 20 DAY CORPORATE SERVICE 

(a) GENERAL FORMS

CASE NUMBER 

PLAINTIFF(S) VS. DEFENDANT(S) SERVICE 

THE STATE OF FLORIDA: 

To Each Sheriff of the State: 

YOU ARE COMMANDED to serve this summons and copy of the complaint or petition in this action on 

defendant(s): _______________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

Each defendant is required to serve written defense to the complaint or petition on 

Plaintiff’s Attorney: __________________________________________________________ 

CLOCK IN 

whose address is: ___________________________________________________________ 

within 20 days “ Except when suit is brought pursuant to s. 768.28, Florida Statutes, if the State of Florida, one of its agencies, 

or one of its officials or employees sued in his or her official capacity is a defendant, the time to respond shall be 40 days. 

When suit is brought pursuant to. 768.28, Florida Statutes, the time to respond shall be 30 days.” after service of this summons 

on that defendant , exclusive of the day of service, and to file the original of the defenses with the Clerk of this Clerk Court either before 

service on Plaintiff’s attorney or immediately thereafter. If a defendant fails to do so, a default will be entered against that defendant for 

the relief demanded in the complaint or petition. 

HARVEY RUVIN 

CLERK of COURTS 

DEPUTY CLERK 

DATE 

AMERICANS WITH DISABILITIES ACT OF 1990 

ADA NOTICE 

“If you are a person with a disability who needs any accommodation in order to 

participate in this proceeding, you are entitled, at no cost to you, to the provision of certain 

assistance. Please contact Aliean Simpkins, the Eleventh Judicial Circuit Court’s ADA 

Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1st Avenue, Suite 2400, 

Miami, FL 33128; Telephone (305) 349-7175; TDD (305) 349-7174, Email 

ADA@jud11.flcourts.org; or via Fax at (305) 349-7355, at least seven (7) days before your 

scheduled court appearance, or immediately upon receiving this notification if the time 

before the scheduled appearance is less than seven (7) days; if you are hearing or voice 

impaired, call 711.” 

CLK/CT. 314 Rev. 09/19 Clerk’s web address: www.miami-dadeclerk.com 



X

JESUS GABRIEL GELLA HEALTHCARE REVENUE RECOVERY GROUP, LLC

HEALTHCARE REVENUE RECOVERY GROUP, LLC

Darren R. Newhart, Esq. 

14611 Southern Blvd. #1351 Loxahatchee, FL 33470

Filing # 155284977 E-Filed 08/15/2022 09:06:46 AM Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 18 of 19
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

__________________________________________________________________________ 

__________________________________________________________________________ 

 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

DIVISION 

 CIVIL 

 DISTRICTS 

 OTHER 

SUMMONS 20 DAY CORPORATE SERVICE 

(a) GENERAL FORMS

CASE NUMBER 

PLAINTIFF(S) VS. DEFENDANT(S) SERVICE 

THE STATE OF FLORIDA: 

To Each Sheriff of the State: 

YOU ARE COMMANDED to serve this summons and copy of the complaint or petition in this action on 

defendant(s): _______________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

Each defendant is required to serve written defense to the complaint or petition on 

Plaintiff’s Attorney: __________________________________________________________ 

CLOCK IN 

whose address is: ___________________________________________________________ 

within 20 days “ Except when suit is brought pursuant to s. 768.28, Florida Statutes, if the State of Florida, one of its agencies, 

or one of its officials or employees sued in his or her official capacity is a defendant, the time to respond shall be 40 days. 

When suit is brought pursuant to. 768.28, Florida Statutes, the time to respond shall be 30 days.” after service of this summons 

on that defendant , exclusive of the day of service, and to file the original of the defenses with the Clerk of this Clerk Court either before 

service on Plaintiff’s attorney or immediately thereafter. If a defendant fails to do so, a default will be entered against that defendant for 

the relief demanded in the complaint or petition. 

HARVEY RUVIN 

CLERK of COURTS 

DEPUTY CLERK 

DATE 

AMERICANS WITH DISABILITIES ACT OF 1990 

ADA NOTICE 

“If you are a person with a disability who needs any accommodation in order to 

participate in this proceeding, you are entitled, at no cost to you, to the provision of certain 

assistance. Please contact Aliean Simpkins, the Eleventh Judicial Circuit Court’s ADA 

Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1st Avenue, Suite 2400, 

Miami, FL 33128; Telephone (305) 349-7175; TDD (305) 349-7174, Email 

ADA@jud11.flcourts.org; or via Fax at (305) 349-7355, at least seven (7) days before your 

scheduled court appearance, or immediately upon receiving this notification if the time 

before the scheduled appearance is less than seven (7) days; if you are hearing or voice 

impaired, call 711.” 

CLK/CT. 314 Rev. 09/19 Clerk’s web address: www.miami-dadeclerk.com 



X

JESUS GABRIEL GELLA HEALTHCARE REVENUE RECOVERY GROUP, LLC

HEALTHCARE REVENUE RECOVERY GROUP, LLC

Darren R. Newhart, Esq. 

14611 Southern Blvd. #1351 Loxahatchee, FL 33470

Filing # 155284977 E-Filed 08/15/2022 09:06:46 AM

8/25/2022

Case 1:22-cv-22900-KMM Document 1-2 Entered on FLSD Docket 09/12/2022 Page 19 of 19