HomeMy WebLinkAbout09-2940Our File No.: 191785
APOTHAKER & ASSOCIATES, P.C.
1 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.
TIONIE KOCH
39 W LOCUST ST
MECHANICSBURG, PA 17055
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. 09 _ a9yo 05wiCrink
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.: 191785
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.
TIONIE KOCH
39 W LOCUST ST
MECHANICSBURG, PA 17055
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 09- d 4 q d & ra
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 TIONIE KOCH, an adult individual residing at 39 W LOCUST ST
MECHANICSBURG, PA 17055.
3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account
#6019181842447496; 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 $5,303.13. 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".
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
$5,303.13 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER & A^CIATES, P.C.
A Law Firm EngkedAn Debt
BY:
Dated: 5/5/2009 David J. Apothaker, Esquire
Our File No.: 191785
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 urp4orn falsification to authorities.
David J.
for Plaintiff
DATE: 5/5/2009
AFFIDAVIT OF CORRECTNESS
STATE OF ILLINOIS COUNTY OF COOK
BEFORE ME, on the day and date set forth below, the undersigned Notary, being
qualified and commissioned in and for the county and state aforesaid, personally came and
appeared - r who being duly sworn,
did depose and say:
Affirant is the l `, 'l at
Arnow Financial Services. LLC ("Arrow"). On 4;29/2008, Arrow purchased Account Number
6019181842447496 {"the Account'") from. GE MONEY BANK. Based on the account
information provided to Arrow. the Account was owed by TIONIE KOCI-i, (the `'Debtor").
Based upon the account information provided to Arrow by GE MONEY BANK. as of
/29,12008, the balance owed by they Debtor can the Account, which Account Arrow subsequently=
sold to CACI1, LLC was S 4.228.87.
Executed this day of ?. _.200{), at Cook County, Illinois,
Shorn to and Subscribed Before me
NOTARY STAMP:
This day of '1'... 2009.
r?
A
Notary Public
"OFFJCI.,AL SLAG"
r
CACH, LLC
TIONIE KOCH
39 W LOCUST ST
MECHANICSBURG, PA 17055
STATEMENT OF ACCOUNT
Debtor's Name:
Account Number:
Original Creditor:
Balance Due:
Our File No.: 191785
TIONIE KOCH
6019181842447496
GE MONEY BANK
$5,303.13
EXHIBIT "A"
CS)
FJLE 0,,-, ,'fCE
OF 7 i PPIOT r'$10 AA'f
2009 I'Ay 11 P11 f: 0 7
r
t r i"Jiro
41$. So Pp A`W
Cop I waoaf
R* aA445S
Sheriffs Office of Cumberland County
R riff Thomas Kline 0? ,,, of lialb"rf? ? Edward L Schorpp
4 11 Solicitor
J,
Ronny R Anderson Jody S Smith
Chief Deputy ='? Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/12/2009 09:15 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 12,
2009 at 2115 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Tionie Koch, by making known unto Doreen Shoop, mother of defendant at 39 W.
Locust Street Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.00 SO ANSWERS,
May 13, 2009 R THOMAS KLINE, SHERIFF
2009-2940 By
Cach, LLC Depu Shen
VS
Tionie Koch
- r
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