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Home My WebLink About10-0774 FT C? C?v I"M 202, Ft3-1 :Gf --; 71, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH LLC successor in interest to GE MONEY BANK, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO. to - 7'14 Civ;l term vs. Plaintiff, ROSEMARY WALKERand BENJAMIN L WALKER, Defendants. TYPE OF PLEADING: Complaint in Civil Action CODE: FILED ON BEHALF OF: Plaintiff, CACH LLC successor in interest to GE MONEY BANK COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 Reed James Davis Pa. I.D. #64343 DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-489-1400 CA000289 O F:\DOCS\181\100121COMP ECS 4qa. oo pD ATT-( C4c7tt' 10 to 13 a-?17o53 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH LLC successor in interest to GE MONEY BANK, NO: Plaintiff, VS. ROSEMARY WALKERand BENJAMIN L WALKER, Defendants. NOTICE TO DEFEND 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 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 HELP. LAWYER REFERRAL SERVICE, Cumberland County Bar Associat 32 South Bedford Street Carlisle, PA 17013 Telephone: 800/990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACH LLC successor in interest to GE MONEY BANK, NO: Plaintiff, VS. ROSEMARY WALKER and BENJAMIN L WALKER, Defendants. COMPLAINT IN CIVIL ACTION AND NOW comes CACH LLC successor in interest to GE MONEY BANK by and through their counsel, Davis Davis Attorneys, a professional corporation, and makes this Complaint against the named Defendant of which the following is a statement: 1. CACH LLC is a company with one of its principal offices located at 4340 S Monaco St 2nd fl, Denver CO 80237; hereinafter referred to as "Plaintiff'. 2. ROSEMARY WALKER is an adult individual whose last known residence is 41 RIDGE DR CARLISLE PA 17015-9721, hereinafter referred to as "Defendant". 3. BENJAMIN L WALKER is an adult individual whose last known residence is 41 RIDGE DR CARLISLE PA 17015-9721, hereinafter referred to as "Defendant". 4. On or about November 16, 2006, Defendants applied for and received a Credit Card and agreed to be responsible for the repayment for any charges, cash advances, interest and fees. 5. The said Agreement was assigned for value to the Plaintiff. 6. The Defendants are in default to Plaintiff for failing to make payments for the balance outstanding. 7. The outstanding balance which remains due and owing to the Plaintiff by the Defendant is $17,196.35 as set forth in the statement of account which is marked Exhibit "A" attached hereto and made a part hereof. 8. Interest accrues at the rate of 29.99% per year. Interest has accrued through January 22, 2010 in the amount of $5,520.64. 9. Demands for payment have been made upon Defendants by Plaintiff, but Defendants have failed or refused to pay. WHEREFORE, Plaintiff demands judgment against Defendants, jointly and severally, in the sum of $22,716.99 with additional interest on the balance of $17,196.35 at the rate of 29.99% per annum from January 22, 2010 until the date of judgment and interest on the judgment amount at 6.00% per annum thereafter. DAVIS DAVIS ATTORNEYS a professional corporation By: D (L-- Reed Ja s Davis Attorney for Plaintiff 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-489-1400 CA000289 F:\DOCS\181\100122.COMP ECS Account Number 00191/03 8624 OT40 03 11111111 a. ?? Print ettaagaa on idea ROSEMARY K WALKER t5C7203152497501 BENJAMIN L WALKER Mail Paymatrb - GE MONEY BANK 41 ROOS DR PO BOX 9WW1 CARLISLE PA 17015.9721 ORLANDO, FL 32595-OWI ! 170159721412 ! !328960061618! se.a2a.oo 40.00 oularzoo9 $0.00 so.oo so.oo Fill in Amount $ p Mw CtKnPNtely: P/ynteM dun teolWeB 0.00 aeSl did. Pteare P/Y the teal d W amount PROSPYLY. Cbach at. awn" hoe N N aI.#nea111 and 00000000060600 000000000000000 000601918 0385249 78062 Per eNine M err -9801161Mearyl0e.eem Y NdOae we ewp0n vM )cur 0111! WOE MONEY 4M1K a e1e We 0r 4heek wa CARE CREDIT/GEMB GE Money ForCUabmarServieewMwonline atWWW.Usonllnesarvice.corrl oreaa:7 866191-7a601o monwu r mmate yolen ACCo rlt Number StMemant Date Payment Due Date Total Mintnum Payment Due Gays This Period PAYMENT DUE By a P.M. ON THE DUE DATE VA may onoved your p/ymaM lino an ebdranb debit. ace reverse skis. Previous Bdance 517,196.35 New Purchases / Balance Transfers 50.00 • Payments $0.00 46 Credits, Fans 8 Aqusimenla (nw) b17.196.36- +% FINANCE CHARGE/ $0.00 Transaction Fees (tst) New Balance $0.00 Credit Limit 115,600.00 Avei(ada Credit $0.00 Train Dale Post DaN RNmence Ntmtbar DesortpWrl Atllounl 03rA4R008 0334r300e F9072002K000ftM CHARGE CM ACCOUNT-PRINCIPALS 30,009.03 CR 03041200/ 03rawaft Ff0Y10029000/a1ty0 CHAROECFFAOCCUNTFINANCECHARGES' 19,117.32CR H" Your FINANCE CHARGE Was Calculated Competed on Daily 1O) Comspwrdine Average Cagy Partook; Annual Principal Rote Pen entepe Perim! FINANCE CHARGE Batema Rain Purtywaa torn o.aut74c ? z9.119i w.oo ANNUAL PERCENTAGE RATE -Purchases 29.80% Total Periodic PWANC9 CHARGE 3C.0o in!1480 b pralert your x=urdpAvaoy, we ere unable b provldo tut mmt Wwx atlon to wW4i other Nan the cordtlol Hor(s) or an atahortted party. If you vdah to permit us b speak to an authorized party such as a spouse shout your accown, plows serkl writRt authorization to the Gon" Irq!irks addrwa If you pay the "Suggested PaymenP amount you will briny your accourd below your credit limit and avoid additional Overlltnk Fees. YOUR PERIODIC RATE AND ANNUAL PERCENTAGE RATE MAY VARY. 'NOTICE: $ea rewam sore and /ddarmal peons 0r"I tar trp"ne nromletion concamtrt9 your amount 5302 P9o t 3 23 090324 ZXMGx 1 of 3 9072 0300 -Es d:9a90x important Notice Regarding Your OE Money Bank Credit Card Account March 2009 Please mad this Notice easefully and retain it for your records This Notice changes the 68owing terms 046ur GE Mrasy BankCrede Card Agree me nt governing the Account m6nod lain the Enclosed Statement The changes veil be ofboWe on the Rest day of your A012009 biting cycle. Alot6ertarms ofyour Agne men! remain the sane t Late Payment Fa*. The Late Payment Fee will increase from $29 to 529.99 for a balance of $249 99 or Iasi and from 53910 $79.99 lots balance 01`1250 00 or more A Other Pees The Returned Check Fee, Resumed Loan Check Fee and Stop Payment Fee -1 increase Rom $39 to $39.99. EXHIBIT hummommommono? Ityou have any questions about 9+it H06M Pk us call the embmer se rNte somber as toted on fo9r Statement. ACCOUNT NUMBER 501918D38524 9780 STATEMENT DATE 03/2412009 Remember YOU rgt wWV an CW*Credrt again and again to loot WWI" your bml br you and yW snWe 1amlly mh 75,000 proAUM nsdamido and Il WWo pw#aM Warm avasabi% ttwre's naging stopping you There are so cowry ways to use CmeCredit, wef ag d them can help you a awe a heelthfar, happier you. Dental treatmarvs to help you NOW up a mom with your smile, LASIK surgery and vision ewe so yoUll always hava a dew perspective and cosmsuc pr s to ertwas your nutwW beauty. Ard wwrg sr, you can aways amirg orr CareCredit for your pots - far gruel care CALL 1,8E6IIg3-?M TO FIND A PROVIDER NEARYOtII CARBCREDIT..,HEALTHCARE FINANCING ON YOUR TERMS, $here your opinWrsf Join the Ca,aGadt Add- o--t a10] a,p 1 c 33 090134 ZXIIMS ] of 1 soil 0]OO c625 112F5]0] VERIFICATION I, Reed James Davis, state that I am not a party to the action but that at the request of the Plaintiff, and based upon knowledge, information, records, and documents supplied to me by the Plaintiff, the averments set forth in the foregoing Complaint are true. A Verification executed by Plaintiff can be supplied at tim, trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: l Reed Jame avis, Esquire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff yttt? ?,1 4ttn€(??r? TARY Jody S Smith Chief Deputy Edward L Schorpp Solicitor 2010 FF8 16 M 9.61 Cach, LLC vs. Rosemary Walker Case Number 2010-774 SHERIFF'S RETURN OF SERVICE 02/0412010 03:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on February 4, 2010 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Rosemary Walker, by making known unto herself personally, at 41 Ridge Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. 02/04/2010 03:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on February 4, 2010 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Benjamin L. Walker, by making known unto Rosemary Walker, Wife of defendant at 41 Ridge Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.40 February 08, 2010 SO ANSWERS, ??'NY R ANDERSON, SHERIFF By epdty'Sheriff U "f Tap