E-FILED 2015 JAN 20 4:52 PM SAC - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT FOR SAC COUNTY

CACH, LLC,
Plaintiff,

Case No. _________________

vs.

PETITION AT LAW

David N Kroll,
Defendant(s).
________________________________
COMES NOW the Plaintiff, CACH, LLC, and for its cause of action against the
Defendant(s), alleges and states as follows:
1.

Plaintiff is a corporation organized and existing under the laws of the State of

Colorado.
2.

Defendant(s) reside(s) in Sac County, Iowa.

3.

At the request of Defendant(s), Plaintiff's assignor, WELLS FARGO BANK, N.A.,

issued a credit card or loaned money to Defendant(s), subject to credit terms agreed to
by Defendant(s).
4.

Defendant(s) used said credit card or borrowed said monies from Plaintiff's

assignor and said assignor extended credit to Defendant(s) pursuant thereto.

5.

Defendant(s) is/are in default of said credit terms for failure to make payments to

said assignor when due.

6.

Any required notice to cure said default was given to Defendant(s), Defendant(s)

has/have failed to cure said default and Plaintiff has declared the entire balance due
and payable from Defendant(s) to Plaintiff as set forth herein. A copy of said notice is
attached hereto and made a part hereof by this reference.
7.

Defendant(s) received and accepted a statement or statements from Plaintiffs

assignor reciting the balance due from Defendant to Plaintiffs assignor at the time of
each such statement and Defendant(s) did not object to their accuracy or any objection
was resolved, resulting in the balance due as set forth in the final charge-off statement
attached hereto and made a part hereof by this reference.
8.

For valuable consideration, said assignor assigned said account to Plaintiff as set

forth in the affidavit of sale attached hereto and made a part hereof by this reference.
9.

Plaintiff attaches hereto such other and further affidavits, verifications and
This communication is from a debt collector and is an attempt to collect a debt.
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E-FILED 2015 JAN 20 4:52 PM SAC - CLERK OF DISTRICT COURT

statements, whether one or more, in support of the balance due, assignment and
identification of Defendant(s) as described herein, said documents being made a part
hereof by this reference.
10.

After deducting all credits, there remains due and owing from Defendant(s) to

Plaintiff the principal amount of $4,790.64, plus interest in the amount of $1,163.82.
11.

Due demand for payment was made by the Plaintiff on Defendant(s), but

Defendant(s) have/has failed, refused or neglected to pay the full amount due.
12.

Defendant(s) is/are not enrolled in the military service of the United States of

America or its allies.

WHEREFORE, Plaintiff prays for judgment against the Defendant(s) (and each of
them) in the principal amount of $4,790.64, plus interest in the amount of $1,163.82
together with post-judgment interest and court costs.
DATED: November 25, 2014

CACH, LLC, Plaintiff,

By: /s/ John T. Rogers____________

John T. Rogers, #AT0010741
John C. Bonewicz, P.C.
350 N. Orleans St. Suite 300
Chicago, IL 60654
866-427-4027

This communication is from a debt collector and is an attempt to collect a debt.

*Q21936-IAC1-1-*