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HomeMy WebLinkAbout13-1375 Nudelman, Klemm, & Golub, P.C. Attorney(s) for Plaintiff(PKN00642) 425 Eagle Rock Avenue - Suite 403 Roseland, NJ 07068 (973) 618 -0000 [tel.] 073) 618 -0647 [fax] CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive PLEAS RICHMOND VA 23286 CUMBERLAND COUNTY, PENNSYLVANIA vs. DOCKET NO.. I CATHERINE M BON 420 BOXWOOD CT - MECHANICSBURG PA 17050 -4608 ~ - r -- TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFER/ENTER JUDGMENRENTER APPEARANCE Please enter Robert L. Baroska, 3` Esquire and the Law Office of Nudelman, Klemm & Golub, P.C. as counsel of record for Plaintiff, CAPITAL ONE BANK in the above captioned matter. Kindly enter judgment, indexing the same as captioned above, in favor of the Plaintiff and against the Defendant(s), CATHERINE M BON, in the amount of $3,7 in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000135 -08, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $2,888.38 INTEREST (from March 27, 2008) $858.45 COSTS (Expended post - judgment) $31.25 Less Payments /Adjustments made -$.00 Total: $3,778.08 Nudetman, Klemm and Golub, P.C. By _ Robert L. Baroska 3` Esquire P.A. ID # 306728 (n(- ff Department of Defense Manpower Data Center Results ae of Mar I"- 2 01306103P SCRA 3 0 'tatus .Report I UXNW ;r € try S rvice x�ember� Civil Relief :�ct Last Name: BON First Name: CA THERINE Middle Name: M Active Duty Status As Of: Mar -12 -2013 On Aetive Duty On Active Duty Status Date Acvve Duty Start Date Active Duty End Date status service Component NA NA - No NA —. This response reflects the individuals' active duty status based on the Aclwe Duly Status Date Left Active Duly,Wilbn 367. Days of Active Duty Status Dale Acvve Duty start.Daie Acvve -Duty End Date. Status Service CompDnem NA NA No NA -his response refects where the Individual left active duty. status within W days preceding the Acllve Duly Status Date The Member or His/Her Unn Was Norti*d of a. Future Call -Up to Active Duty on Active Duty Status Date Onion Noli±icatlon Stan 'Dale Order NolAcation End Dale status Service Componenl NA NA No — -- NA 1 his response reflects whether the Individual or his/her unit has received early notdication to report for active cuty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public; Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Aalllk� j Mary M. Snavely Dixon, Director ✓ Department of Defense Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 2235C File #: PKNO0642 CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive COMMON PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA vs. DOCKET NO.: CATHERINE M BON 420 BOXWOOD CT MECHANICSBURG PA 17050 -4608 VERIFICATION /AFFIDAVIT OF NON - MILITARY SERVICE The undersigned does hereby verify, subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities, that the undersigned is the attorney for the Judgment Creditor, CAPITAL ONE BANK; with a mailing address of c/o Nudelman., Klemm and Golub, P.C., 425 Eagle Rock Ave. - Suite 403, Roseland NJ 07068; and that the last known address of the Judgment Debtor(s), CATHERINE M BON, is believed to be: 420 BOXWOOD CT MECHANICSBURG PA 17050 -4608 ; and that the Judgment is valid, enforceable and unsatisfied, and that the facts set forth in the foregoing Praecipe are true and correct to the best of the undersigned's knowledge, information and belief. The undersigned, being duly sworn according to law, deposes and says that to the best of his knowledge information, and belief the above captioned Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Service Members Relief Act, 50 App. U.S.C. § 501 et. seq. (amended in 2004). Nudelman, Klemm and Golub, P.C. PEAR 12 2013 - Robert L. Baroska 3 ", Esquire Attorney for Plaintiff File 0 PKNO0642 CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive PLEAS RICHMOND VA 23286 CUMBERLAND COUNTY, PE'."SYLVANIA vs. DOCKET NO.: CATHERINE M BON 420 BOXWOOD CT MECHANICSBURG PA 17050 -4608 NOTICE OF JUDGEMENT OR ORDER TO: ( ) Defendant ) Garnishee You are hereby notified pursuant to Pa. R.C.P. 236 that the following order of judgment was entered against you on: notified of ))) kj 20 13 O Judgment in the amount of $3,778.08 plus costs. ( ) Entry of Judgment of: Court Order ( ) Non -Pros ( ) Confession > Default Garnishee ! ) Verdict ( ) Arbitration Award ( ) A copy of "all documents filed with the Prothonotary in support of the within judgment are enclosed. If you have any questions concerning this notice please contact Plaintiff's counsel, Nudelman, Klemm. & Golub, P.C. at 973/618 -0000. BY ORDER OF JPROONOTARY: , 0"D� By: PROT Y R D _PUTY) CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: vs. -- CATHERINE M BON 420 BOXWOOD CT MECHANICSBURG PA 17050 -4608 CERTIFICATE OF SERVICE 1'j certify that on this J,? day of ' " 20 �� > I mailed a true and correct copy of the foregoing praecipe for entry of judgment upon the party(s) or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: CATHERINE M BON 420 BOXWOOD CT MECHANICSBURG PA 17050 -4608 ' t I ilc 4:1KN00642 COMMONWEALTH OF PENNSYLVANIA Notice of JudgmentManScript Civil COUNTY OF CUMBERLAND CASE! Mag. Dist. No: MDJ- 09 -3 -04 Capital One Bank MDJ Name Honorable Paula P. Correal V Address: 5275 East Trindle Road Catherine Bon Suite 110 Mechanicsburg, PA 17050 Telephone: 717- 697 -2201 Paul John Klemm, Esq. Docket No: MJ- 09304 -CV- 0000135 -2008 Nudelman Nudelman & Ziering Case Filed: 2/21/2008 425 Eagle Rock Ave Roseland. NJ Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09304 -CV- 0000135 -2008 Capital One Bank Catherine Bon Default Judgment for Plaintiff 03/27/2008 Judgment Summary Participant Joint /Several Liability Individual Liability Amount Capital One Bank $0.00 $0.00 $0.00 Catherine Bon $0.00 $2,888.38 $2,888.38 Judgment Detail ( " Post Judgment) In the matter of Capital One Bank vs. Catherine Bon on 3/27/2008 the judgment was awarded as follows: Judgment Component Joint /Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,798.88 $2,798.88 Costs $0.00 $89.50 $89.50 Grand Total: $2,888.38 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY /CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT /TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. n ., Date r Ma Isterial District Jude I certify that this is a true and correct copy of the record of the proceedirfg ontain g the 1u gm t. a- 1q_ 13 Date M I ;strict Judge MDJS 315 Page 1 of 2 Printed: 02/19/2013 9:24:02AM Capital One Bank Docket No.: MJ- 09?04 -CV- 0000135 -2008 V. Catherine Bon Participant List Plaintiff(s) Capital One Bank C/O Paul Klemm, Esq. 50 Harrison Street Suite #206 Jam ;v Hoboken. NJ 07030 c }� Defendant(s) Catherine Bon w 420 Boxwood Court Mechanicsburg, PA 17050 - Complainant's Attorney(s) Paul John Klemm, Esq. Nudelman Nudelman & Ziering 425 Eagle Rock Ave Roseland, NJ MDJS 315 Page 2 of 2 Printed: 02/19/2013 9:24:02AM r MMONWEALTH OF PENNSYLVANIA *cMiN Y OF CUIMsRi.AND CIVIL ACTION HEARING NOTICE Lag. Dist- No.: E_ 09 PLAINTIFF: NAM and ADDRESS rCAPITAL ONE e MDJ Name. Hon. 50 HARRISOY STREET APT /STE 206 THOMAS A. PLACEY C/o PAUL KLEIIO[, ESQ. Address 104 S SPORTING HILL -RD L"OKEN, NJ 07030 MCHANICBBURG, PA VS. --i DEFENDANT: NAME and ADDRESS J Telephone: (717) 761-8230 17 0 5 0 - rBON, CATHERINE -I 5 420 BOXKOOD COURT MECHANICSBURG, PA 17050 i CAPITAL ONE BANK L -� 50 HARRISON STREET APT /STE 206 Docket No.: C7- 0000135 -08 C/O PAUL KLMM, ESQ. Uate Filed: 2/21/08 4 HOBOKEN, NJ 07030 1 , j A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 3/27/08 Place: DISTRICT COURT 09 -3 -04 104 8 SPORTING HILL'RD Time: 8s45 AN XZCHANICSBURG, PA 17050 717 =-761 -8230 - .._ OTMEtO D, ENDANT It you intend to enter a defense to this complaint, you should so notify this office Immediately at the above telephone number. 'i YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. +i If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five days before the date set for the hearing. Pursuant to Pa.R.C.P.D.J. No. 342(6)(2); no claim by the defendant will be permitted in a supplementary action filed for failure of judgrhent creditor to .enter satisfaction. �I NOTICE TO PLAINTIFF i j Pursuant to Pa.R.C.P.D.J. No. 318, you or your attorney will be notified if the defendant gives notice of his /her j intention to defend. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and Its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 3086 - 05 DATE PRINTED: 2/21/08 11:26:18 AN `+;: COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Mayiabrial Diamlct Number. PLAINTIFF: NAME and ADDRESS 09 -3 -04 I CAPITAL ONE BANK, H ON. THOMAS A. PLACEY M0.1Nam�:N c/o 50 HARRISON ST., STE. 206, H Awrau: 104 SOUTH SPORTING HILL RD. HOBOKEN, NJ 07030 MECHANICSBURG, PA 17050 Talaphom.: 717- 761 -8230 DEFENDANT: NAME &W ADDRESS 7CATHERINE M BON 7 420 BOXWOOD CT MECHANICSBURG, PA170504608 L. J Docket No: Clr Date Filed: W" AMOUNT DAT PAID FILING COSTS $ x,50 / /Oa POSTAGE SERVICE COSTS $ CONSTABLE ED. $ TOTAL $ (� Pa.R.C.P.D.J. No 206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for S 2798.88 together with costs upon the following claim (Civil fines must Include citation of the statute or ordinance violated): Defendant owes Plaintiff the above referenced sum for: Breach of contract on credit card account number 4121741631527517 ; Money due and owing on an account stated; Money due and owing on an open book account; Reasonable value of goods sold and delivered and /or services rendered; and Unjust enrichment The account was opened on 12/01/99 and the account charged -off on05/24/06. 1, PAUL KLEMM verify that the facts set forth in this omplaint are true and correct to the best of my knowledge, Information, and belief. This statement is made subject to pe ald If Section 4904 of the Crimes Code (18 PA. C.S § 4904) related to Insworn falsification to authorities. Plaintifrs (Signature of Plaintiff or Authorized Agana Attorney: PAUL KLEMM Address: 50 HARRISON ST., STE. 206, Telephone: (201) 217 -3400 NOBOKEN, NJ07030 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 30BA -05