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IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI
AND PLAINTIFFS
VS. NO.
DEFENDANT
COMPLAINT
COMES NOW , Plaintiff, and files this complaint against the Defendant, ,
and for cause of action would show unto the Court the following, to - wit:
I.
That and are both adult resident citizens of County, Mississippi. The
Defendant, , is a Mississippi corporation with its principal place of business being located
at , , Mississippi. Service of process may be served upon the Defendant by serving
its president, , , , Mississippi.
II.
Plaintiff, , would show that he/she purchased a policy of hospital insurance from
the Defendant bearing contract number . That said insurance policy had an effective date
of , . Plaintiffs would further show that at all times herein complained of the
premium on said policy was paid in full.
III.
On or about , , sustained an injury when he/she sat down on a
box that had been left in his/her car. Plaintiff was experiencing severe pain and went to
the emergency room of the in , Mississippi where he/she was treated and released.
Plaintiffs would further show that on or about , was still suffering
extreme pain in the coccygeal area and went to see in , Mississippi.
admitted to the on , where he/she was confined until
, .
IV.
Plaintiff was still undergoing extreme pain in the coccygeal area on or about
, and he/she went to see his/her family physician, , in , Mississippi.
immediately hospitalized in the in , Mississippi where he/she was
confined until , .
V.
Plaintiffs would show that claims were submitted to the Defendant for the aforesaid
hospital confinements and doctor bills. The defendant paid the claims with the exception of the
claim from the for ordered and medically necessary confinement from
, to , .
VI.
Plaintiffs would show that the Defendant paid the claim to , attending
physician who ordered his/her hospital stay in the but refused to pay said hospital claim in
the amount of $ . Plaintiffs would further show that a pre - certification of
hospitalization was obtained from the Defendant.
VII.
Plaintiff contacted the Defendant on several occasions concerning their
non - payment of his/her hospital claim and was led to believe that the claim would be paid.
Finally on , , months after his/her hospital confinement to the ,
Plaintiffs received a letter from the Defendant signed by , legal counsel, stating that an
outside consulting physician's opinion was that his/her hospitalization was not medically
necessary.
VIII.
Plaintiffs would show that was admitted to upon the orders of , a
licensed physician in the State of Mississippi. was not physically seen by the defendant's
outside consulting physician.
WHEREFORE, PREMISES CONSIDERED, Plaintiff demands judgment of and from
the Defendant in the amount of $ actual damages and $ punitive damages for the
willful, wanton and malicious actions of the Defendant in refusing to pay Plaintiff just
and medically necessary hospital confinement claim to the .
Respectfully submitted,
and
BY: _________________________________________
OF COUNSEL:
__________________________________________
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