480150 24TH JUDICIAL DISTRICT COURT FOR JEFFERSON '3 STATE OF LOUISIANA 'DIAGNOSTIC MANAGEMENT AFFILIATES PPO LLC "734* 1th VS MCQUAIG ASSOCIATES LLC AND SCOTT MCQUIAG ?tggumED SUIT FOR BREACH OF CONTRACT .1 The petition of DIAGNOSTIC MANAGEMENT AFFILIATES PPO LLC, an entity Qanized and doing business under the laws of the State of Louisiana in the Parish of Orleans respectfully represents that: 1. Made Defendants herein are a) MCQUAIG ASSOCIATES LLC, a Louisiana lawfirm domiciled and authorized to do business in the Parish of Jefferson, State of Louisiana, and b) SCOTT MCQUIAG a natural person of the full age of majority and licensed Louisiana attorney domiciled and/or doing business in the Parish of Jefferson, State of Louisiana. 2. On or about March 9, 2005, Defendant, MCQUAIG ASSOCIATES LLC, entered into the 0 attached agreement with plaintiff, DIAGNOSTIC MANAGEMENT AFFILIATES PPO LLC. 3. The purpose of the agreement was for the plaintiff to arrange medical services for the defendants? personal injury clients. 4. The plaintiff arranged certain medical procedures indicated in the attached documents for the defendants? clients pursuant to the agreement. 5. As of April 30, 2015, a total of $88,443.78 is past due and owing to DIAGNOSTIC MANAGEMENT AFFILIATES PPO LLC per the attached itemization. This amount consists of $81,702.61 in principal and $6,741.17 in service fees. ?0 6. MCQUAIG ASSOCIATES LLC, is in default and has not paid despite amicable demand. 8. Defendant, SCOTT MCQUAIG personally guaranteed payment. 7. The plaintiff is entitled to additional service charges at the rate of 15% per annum on the principal from May 1, 2015 until paid. 9. Defendant, SCOTT MCQUAIG personally guaranteed payment. 10. Per the agreement the Plaintiff is entitled to reasonable attorney's fees and all costs of this proceeding. 1 1. It is respectfully represented that 25% of the amount due is a reasonable minimum attorney's fee. 9102 9? 130 GESVWI WHEREFORE PETITIONER PRAYS for Judgment herein in favor of DIAGNOSTIC MANAGEMENT AFFILIATES PPO LLC and against defendants, MCQUAIG ASSOCIATES LLC AND SCOTT MCQUAIG, jointly and insolido, in the principal sum $81,702.6lp1us accrued service fees in the amount of $6,741 .17, future service fees on the principal at the rate of 15% from May 1, 2015 until paid, a minimum of 25% reasonable attorney?s fees on the aggregate of principal and interest, for all costs, and for all general and equitable relief. COUCH, CONVILLE BLITT, LLC azBradley Chauvin ar #20516) Benjamin G. Lambert (Bar# 33226) Sarena Y. Gaylor (Bar#35141) Remy F. Symons (Bar# 34553) Elizabeth L. Hyman (Bar#35 837) Jeremy Nusloch (Bar#3 2982) Randall C. Roth (Bar#1 1481) Attorney for Plaintiff 1450 Poydras Street, Suite 2200 New Orleans, LA 70112 (504) 83 8-7747 PLEASE SERVE: MCQUAIG ASSOCIATES LLC (Personal Service Only) ThrOugh its agent for service of process SCOTT MCQUAIG 100 LILAC ST METAIRIE LA 70005 And SCOTT MCQUAIG 100 LILAC ST METAIRIE LA 70005 Couch. (LA) fir '1 Sarena Ga lor (LA) 1. Ward candle (MS, TN) i . i Remy Swirls (LA) Fred N. Blilt (IL) .7 . BradleyLCham (LA) 2: 8 Kane 3. Sanders (AL) James (TX) Elizabeth L. Hyman (LA) . . i? Jeremy L. Nusloch (LA) Benjamin G. Lambert (LA, MS. TN) I I I Randall Roth (LA) w. James Sears (AL) Lisa L. Meggs (MS, AL) OfCarmse! Malea A Higdon (MS, AL) J. Scott Loch (LA) 51?3?? Redma? ?0 Attorneys Counselors at Law Mi? 0? (TN) Louisiana 0 0 ??z?iama 0 rIt'etmessee - Texas September 11, 2015 I i Clerk of Court 24th IUDICIAL DISTRICT COURT JEFFERSON PO. Box 10 Gretna LA 70054 Re: DIAGNOSTIC MANAGEMENT AFFILIATES PPO LLC Vs. MCQUAIG ASSOCIATES LLC AND SCOTT MCQUAIG Our File: Client#: 2065 Suit Dear Clerk: Please ?nd enclosed a Petition which we would like ?led in the above matter. Please return to us a conformed copy in the self-addressed envelope attached noting docket number and date of ?ling. Please also issue service as requester?W 5 I: We enclose a check to cover costs of ?ling and thank you for your Very truly yours, COUCH, CONVILLE BLITT LLC Date of Placement: April 22, 2015 9 130 Mailing Address: 1450 Paydras Se, Suite 2200, New Orieans, LA 70112 1" Louisiana: 1450 Poydras Street, Suite 2200, New Orleans, LA 70112 - 866-282-3853 - (1) 504-83 8-0244 Mississaapi: 1301 West Pine Street, Hattiesburg, MS 39401 866-282-3853 - 601-584-8619 Alabama: 1541 Cooper Hill Road, Birmingham, AL 35210- 866-282?3853- (1) 504-838-0244 Tennessee: 144 Second Avenue North, Suite 200, Nashville, TN 37201-866-372-3120-(f) 888-477-8974 Texas: 6200 Savoy Drive, Suite 440, Houston, TX 77036 - 866-282?3853 713-952-8375