The Illinois-based staffing agency Medix Staffing Solutions is suing an aggregate health services provider, Novo Health LLC and its affiliate companies for failure to pay for services rendered. The lawsuit was filed in the Northern District of Illinois earlier this month.

The staffing agency provides staffing services to several industries including healthcare entities like Novo Healthcare LLC. The lawsuit details that Novo health LLC operated alongside several affiliates, all of which entered into an agreement with Medix Staffing Solutions. Upon entering the agreement, the complaint details that Novo Health and its affiliates failed to pay for the services that were contracted out to them. In the complaint, Curt Kubiak is listed as being the CEO and “person in charge of all defendant companies.”

Medix Staffing Solutions details in the complaint that as of mid-January of this year, Novo Health owed a “principal balance of $1,583,273.60.” In addition to the overdue balance, the plaintiff alleges that Novo Health LLC and its affiliates made payments on invoices on an irregular basis.

The two entities entered into a written contract called the “Epic Project Services Agreement.” Under the agreement, the two parties agreed that Medix Staffing would provide its staffing services starting on or around May 11th, 2010. The complaint details that Novo Health LLC agreed to a late fee of 1.5% every month for undisputed invoices. According to the unpaid balance and other records explained in the complaint, all the invoices were undisputed.

The agreement also detailed that Medix Staffing Solutions would have the authority to use a collection service company to recover unpaid balances and “any related legal and collection services fees to the outstanding balance owed.”

Medix contends that Novo Health “utilized the services of human labor while failing to pay for the services of those persons.” They go on to say that Novo Health made promises that they would pay their overdue balance, but have yet to.

“It is in the public interest that the creditors be paid and that the workers be compensated for their labor,” the suit reads. “Particularly by an enterprise involved in providing health care services.”

As detailed by the lawsuit, Novo Health is facing three counts including breach of contract, unjust enrichment/quantum meruit, and action for account stated.