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Home My WebLink About09-4551Our File No.: 211598 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. ELLIE STACHE 501 GLENN ST SHIPPENSBURG, PA 17257-2127 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Oq - g561 (21vt t-Term 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.: 211398 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. ELLIE STACHE 501 GLENN ST SHIPPENSBURG, PA 17257-2127 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 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 ELLIE STACHE, an adult individual residing at 501 GLENN ST SHIPPENSBURG, PA 17257-2127. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #6019181832147015; 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 $2,900.69. 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 $2,900.69 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A O IATES, P.C. Attorney l PI 'ntiff A Law Firm Enea d in Pht CnIl-1;- BY: David J. Apothker, Esquire Dated: 7/1/2009 Our File No.: 211598 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 unworn falsification to authorities. David J. Apot akA, qi Attorney f r Plaintiff DATE: 7/1/2009 f CACH, LLC ELLIE STACHE 501 GLENN ST SHIPPENSBURG, PA 17257-2127 STATEMENT OF. ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due Our File No.: 211598 ELLIE STACHE 6019181832147015 GE MONEY BANK $2,900.69 EXHIBIT "A" Q FIDE or- -T -,IB JAI! -? PH a 30 ?y ???.'-•? , ._..-;fir ?-?. +?8.5o PA Arn Sheriffs Office of Cumberland County R Thomas Kline Sheri OFFICE T?-E °_+'EaIFF Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 2"^9 '_. I ,, ? ^. Cach, LL'., vs. Ellie Stache Case Number 2009-4551 SHERIFF'S RETURN OF SERVICE 07/10/2009 06:06 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2009 at 1806 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ellie Stache, by making known unto Donnie Stache, Husband of defendant at 501 Glenn Street Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 July 13, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF DeputyooSheriff Our File No.: 211598 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CACH, LLC Plaintiff, vs. ELLIE STACHE Defendant. FILE(-(` FIf? 01 THE PROTHC?-110 EV 2011 APR 27 PM 12: 58 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-4551 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASS TES, P.C. Attorneys for Plain ff A Law Firm Engaged in De t Collection By: Dated: 4/14/2011 David J. Apothker, Esquire ?IIIII?III?INIIN-*