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Home My WebLink About09-2722Our File No.: 180221 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CACH, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 04 - vaa aivi < learw NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our File No.: 180221 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CACH, LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O9- a7Aa C..,;c ? •. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CACH, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are AMY KOCH, an adult individual residing at 1875 AERONCA ST CARLISLE, PA 17013-1101. 3. Plaintiff, CACH, LLC, is the Assignee. and Successor in Interest of Account #6019180041527603; and said account was issued to Defendant(s) by GE MONEY BANK, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $2,272.31. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". J 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,272.31 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & S OCIATES, P.C. Attorne for laintiff A Law Firm En ed Debt Collection BY: Dated: 4/27/2009 David J. Apo is er, Esquire Our File No.: 180221 VERIFICATION David J. Apothaker, Esquire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities. DATE: k/M/0 Attorney for Plaintiff AMY KOCH 1875 AERONCA ST CARLISLE, PA 17013-1101 CACH, LLC STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: AMY KOCH 6019180041527603 GE MONEY BANK $2,272.31 Our File No.: 180221 EXHIBIT "A" O 260' i, R 30 PH f - 42 r1Y. 5o PA ArY t3I9 1o ? aa??s Sheriffs Office of Cumberland County R Thomas Kline v??ttitr a4u+r+bp?? Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE T',E --ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05101/2009 10:05 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on May 1, 2009 at 1005 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Amy Koch by making known unto Amy Koch personally, at 1875 Aeronca Street, Carlisle, Cumberland County, Pennsylvania, 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $32.50 May 05, 2009 Docket No. 2009-2722 Cach v Amy Koch SO ANSWERS, R THOMAS KLINE, SHERIFF Deput Sheriff ? rv m -c X -< Law Firm of Allan C. Smith, P.C Attorney I.D. No. 204756 1276 Veterans Hwy, Suite E-1 Bristol, PA 19007 1-888-275-6399 H (215) 428-0666 Attorney for Plaintiff CACH, LLC ) COURT OF COMMON PLEAS 4340 S. MONACO STREET ) CUMBERLAND COUNTY DENVER, CO 80237 ) ) ?J Plaintiff, ) Vs. ) No.. 092722 =M AMY KOCH ) -? `' ?`? 1875 AERONCA ST ) CARLISLE, PA 17013 rv ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of CACH, LLC, the plaintiff in this action. Allan C. Sm , q. I.D No. 204756 Law Firm of Allan C. Smith, P.C 1276 Veterans Hwy- Suite E-1 Bristol, PA 19007 WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdrawal my appearance on behalf of CACH, LLC, the plaintiff in this action. Apotha er & Associates 520 F llowship Road, Suite C 306 Mount Laurel, NJ 08054 Phone: (800) 672-0215 Date: March 14, 2012