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HomeMy WebLinkAbout13-1520 Nudelman, Klemm, & Golub, P.C. Attorney(s) for Plaintiff (PKN09507) 425 Eagle Rock Avenue - Suite 403 Roseland, NJ 07068 (973) 618 -0000 [tel.] (973) 618 -0647 [fax] CAPITAL ONE BANK IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA vs. DOCKET NO.: f 3 -l-5 l.�tyil�l�►-i THERESA M BRUNO 2402 WARREN WAY MECHANICSBURG PA 17050- -726 TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFERIENTER JUDGMENTINTRY OF APPEARANCE Please enter Robert L. Baroska, 3r 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), THERESA M BRUNO, in the amount of $2,647.62, in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000153 -08, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $2,647.62 -$.00 9 Less Payments /Adjustments made - Ev Total: $2,647.62 Nudelman, Klemm and Golub, P.C. By Robert L. Baroska 3` Esquire P.A. ID # 306728 Ito, 5C) PD Any ef` sgabs y �,�a8s 13b COMMONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript 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 Theresa Bruno Suite 110 Mechanicsburg, PA 17050 Telephone 717- 697 -2201 Capital One Bank Docket No: MJ- 09304 -CV- 0000153 -2008 C/O Paul Klemm, Esq. Case Filed: 2/28/2008 50 Harrison Street Suite #206 Hoboken, NJ 07030 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09304 -CV- 0000153 -2008 Capital One Bank Theresa Bruno Default Judgment for Plaintiff 04/17/2008 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank $0.00 $0.00 $0.00 Theresa Bruno $0.00 $2,647.62 $2,647.62 Judgment Detail ( `Post Judgment) In the matter of Capital One Bank vs. Theresa Bruno on 4/17/2008 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,558.12 $2,558.12 Costs $0.00 $89.50 $89.50 Grand Total: $2,647.62 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. Z �� z 4 /// 7 Date/ Senior Magisterial District Judge Paula P. Correa /"tee "s I certify that this is a true and correct copy of the record of the proceedings containing the 1u gment. i Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 02/26/2013 9:37:38AM Capital One Bank Docket No.: MJ- 09304 -CV- 0000153 -2008 v Theresa Bruno Participant List Plaintiff(s) Capital One Bank C/O Paul Klemm, Esq. 50 Harrison Street Suite #206 Hoboken,NJ 07030 Defendant(s) Theresa Bruno 2402 Warren Way Mechanicsburg, PA 17050 -7266 Complainant's Attorney(s) Paul John Klemm, Esq. Nudelman Nudelman & Ziering 425 Eagle Rock Ave Roseland, NJ MDJS 315 Page 2 of 2 Printed: 02/26/2013 9:37:38AM CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive COMMON PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA VS. DOCKET NO.: THERESA M BRUNO 2402 WARREN WAY MECHANICSBURG PA 17050- -726 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), THERESA M BRUNO, is believed to be: 2402 WARREN WAY MECHANICSBURG PA 17050- -726 ; 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. MAR 19 2013 Robert L. Baroska 3` Esquire Attorney for Plaintiff File # PKN09507 Department of Defense Manpower Data Center Results as d Mar -18 -2013 05:5832 SCRA 3.0 Pursuant to Servicememben Civil Relief Act Last Name: BRUNO First Name: THERESA Middle Name: M Active Duty Status As Of: Mar -19 -2013 C)r AeNVe Duty, On AeiN$ Duty Status Data Acave Duty Stan Date `: Active Duty, End bete. . 6181ds Service iomponent;- NA NA " l;trlo.... NA This response reflect& lhe'intllNOUals' active duty status . based on 1he"Aove I;Oy,Status Date Let Active Duty Within a@i Days of Acave Duty Slates Date Active Duty Start Date AdiveDuty End Data. Staius Service l'omponem NA NA No .. NA This response retlecls where the indwtdual left adrva QNy:91gtu8 wittMn:567 :days preceding the 44 ve Duty Status Dale The Member or HiVlisr tl itt Was NoIt ed of a Future Galt Up to Actve Duly on A0tive Duty.Siatus Date', Order Noldicaten Stan Date Order Notifica We Erid-Date Service Componfii NA This response rellects whether the iCldiv ;tluii. , of ttrsmer unit has received ser{y notiliFti60n't0 report for aMe duly Upon searching the data banks of the Department of Defense Manpower Data enter 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. 4 14 4 W w - it Mary M Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 File #: PKNO9507 CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: vs. THERESA M BRUNO 2402 WARREN WAY MECHANICSBURG PA 17050- -726 CERTIFICATE OF SERVICE hereby certify that on this day of ' 20 _L2, I mailed a true and correct copy of the foregoing praecipe for entry of judgm nt upon the party(s) or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: THERESA M BRUNO 2402 WARREN WAY MECHANICSBURG PA 17050 - -726 File #:PKN09507 P J T", COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION; COUNTY OF: .�= HEARING NOT- CE Mag Dist. N PLAINTIFF: NAME an ADDRESS 09 -3 -04 rCAPITAL ONE RUN MDJ Name. Hon. 50 KARRISON STREET APT /STE 20(9; TROK&S A. PLACZY C/O PAUL =LZIOt, ZSQ. Add`ess. 104 S SPORTING HILL RD LHOBOLflR, NJ 07030 . J xzC$ANICSBURG, PA vas. DEFENDANT: NAME and ADDRESS Taieowe (717) 761 -8230 17050 rBRUNO, TKZRESA 1 2402 WARREN WAY ATTORNEY FOR PLAINTIFF s NRCBANICSBUYG, PA 17050 - 7266 PAUL J. LLZIO[ L J 50 HARRISON STREET APT /STZ 206 Docket No.: CV- 0000153 -08 HOBOKZN, NJ 07030 Date Filed: 2/28/08 A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: t Date: 4/17/08 Place: DISTRICT COURT 09 -3 -04 104 S SPORTING HILL RD Time: 8:45 AN NECHANICORORG, PA 17050 717- 761 -8230 NOTICE TO DEFENDANT 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 days before the date seat for the hearing. Pursuant to Pa.R.C.P.D.J. No. 342(8)(2), no claim by the defendant will be permitted in a supplementary act;ior filed for failure of judgment creditor to enter satisfaction. NOTICE TO PLAINTIFF I � 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 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. DATE AOPC 3088 -05 PRINTED: 2/28/08 2 :14 :01 PK COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL CO MPLAINT Magi.te" District Number. PLAINTIFF NAME and ADORM 09 -3 -04 [ CAPITAL ONE BANK, H ON. THOMAS A. PLACEY MDJ "�"'�` " c/o 50 HARRISON ST., STE. 206, H Add...: 104 SOUTH SPORTING HILL RD. HOBOKEN, NJ 07030 MECHANICSBURG, PA 17050 __J vs. Td.phom: 717- 761 -8230 DEFENDANT; NAME rueADORM F THERESA M BRUNO 2402 WARREN WAY MECHANICSBURG, PA17050 -7266 Docket No: W_ o tot s 3 •vs Date Filed: INA AMOUNT DATE PAID FILING COSTS 50' / /( POSTAGE $ t / / SERVICE COSTS S 0.00 CONSTABLE ED. TOTAL $ _ gq .60 bat $ /0 Pa.R.C.P.D.J. No 206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(:) asks judgment against you for S 2558.12 together with costs upon the following claim (Civil tines 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 5178052314589074 ; 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 05/15/03 and the account charged -off on04/08/06. I, PAUL KLEMM verify that the facts set forth In mplaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject of Section 4904 of the Crimes Code (18 PA. C.S § 4904) related to Insworn falaification to authorities. Plaintiff's (awwwre of PIablu f or�iorizM 1Tpsrk} Attorney: PAUL KLEMM Address 50 HARRISON ST., STE. 206 Telephone: (201) 217 -3400 HOBOKEN, NJ07030 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD 30 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 talephone number. We are unable to provide transportation. AOPC 30BA -05 CAPITAL ONE BANK IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY.. RICHMOND VA 23286 PENNSYLVANIA vs. DOCKET NO.: THERESA M BRUNO 2402 WARREN WAY MECHANICSBURG PA 17050- -726 NOTICE OF JUDGEMENT OR ORDER TO: O Defendant ( ) Garnishee You are hereby notified purs . uant to P R.C.P. 236 that the following order of judgment was entered against you on: & day of , 20 13. () Judgment in the amount of $2,647.62, 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 F P H ARY: By: PROTHONOTARY (OR DEPUTY)