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HomeMy WebLinkAbout13-3531 Nudelman, Klemm, & Golub, P.C. Attorney(s) for Plaintiff (PKN32390) 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.: f3 - 3531 , I l Te r m PETER N GEKAS 202 CONODOGUINET AVE CAMP HILL PA 17011 -4114 TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFER/ENTER JUDGMENTIENTRY 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), PETER N GEKAS, in the amount of $4,018.87, in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000551 -08, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $4,018.87 C-) .., , INTEREST (from October 23, 2008) $0.00 -0= w COSTS (Expended post judgment) $0.00 �rn t-. z x � rnr- cnr" Sri Less Payments /Adjustments made -$.00 in CF Total: $4,018.87 4 M -c C Nudelman, Klemm and Golub, P.C. 1 ` - �L By *31.a5Pb A Robert L. Baroska 3r Esquire C -F 1o131(n P.A. ID # 306728 0aq1Qgo N �Ua i l ed COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -3 -04 Capital One Bank Usana MDJ Name: Honorable Paula P. Correal V. Address: 5275 East Trindle Road Peter N. Gekas Suite 110 Mechanicsburg, PA 17050. Telephone: 717 -697 -2201 Paul John Klemm, Esq. Docket No: MJ- 09304 -CV- 0000551 -2008 Nudelman Nudelman & Ziering Case Filed: 8/19/2008 425 Eagle Rock Ave Roseland, NJ Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09304 -CV- 0000551 -2008 Capital One Bank Usana Peter N. Gekas Default Judgment for Plaintiff 10/23/2008 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank Usana $0.00 $0.00 $0.00 Peter N. Gekas $0.00 $4,018.87 $4,018.87 Judgment Detail (*Post Judgment) In the matter of Capital One Bank Usana vs. Peter N. Gekas on 10/23/2008 the judgment was awarded as follows: Judgment Component Joint /Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $3,929.37 $3,929.37 Costs $0.00 $89.50 $89.50 Grand Total: $4,018.87 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 DIST T UDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date i rial District Ju ge certify that this is a true and correct copy of the r o The procee ings contai ng t e 1u gme a, 9 Datd Xagist rict Judge MDJS 315 Page 1 of 2 Printed: 04/25/2013 8:39:04AM Capital One Bank Usana Docket No.: MJ- 09304 -CV- 0000551 -2008 V. Peter N. Gekas Participant List Plaintiff(s) Capital One Bank Usana C/O Paul J. Klemm, Esq. 425 Eagle Rock Ave. Roseland, NJ 07068 Defendant(s) Peter N. Gekas 202 Conodoguinet Avenue Camp Hill, PA 17011-4114 Complainant's Attorney(s) Paul John Klemm, Esq. Nudelman Nudelman & Ziering 425 Eagle Rock Ave Roseland, NJ r� f MDJS 315 Page 2 of 2 Printed: 04/25/2013 8:39:04AM CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive COMMON PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA VS. DOCKET NO.: PETER N GEKAS 202 CONODOGUINET AVE CAMP HILL PA 17011 -4114 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), PETER N GEKAS, is believed to be: 202 CONODOGUINET AVE CAMP HILL PA 17011 -4114 ; 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. JUN ' 2 G1, 3 Robert L. Baroska 3` Esquire Attorney for Plaintiff File # PKN32390 Department of Defense Manpower Data Center Results as of: Jun•12.2013 SCRA 3.0 Pursuant to Smicememben Civil Rehef.Act Last Name: GEKAS First Name: PETER Middle Name: N Active Duty Status As Of: Jun -12 -2013 ;�, AL•ave Duty Start Dated ActNe Duty End Date'; Btetus Serv�ee.Componenr '< r NA NA .:;ado;„ NA This response ref1Kl the ihd"!ndUals eclrve'duty eteYU §;based on the AgH4 DutySfatus Date tettAdlva Cluly W thin 367 Days of AdUVe qury Si 3tus. Date Ac1rvJeDt1iy52arYDeie:. 7 '. A.ctiveDity�'gd'batp? " _Siatus Serdlca�ompoiient:: '� NA - NA NO NA This response reflects where indrvidual left 67:days preceding the 4; Duty Status Date v r T 7he Memberorf9isl HerUndWasNottUedbta' u( OreCall ta )e �_OrdBr Noldivauon Si6n ' iteNott6iatwh End Det9 Statu$ Service GomporleFit., s NA NA This response retlecls whether the thdivlduW_oSl)ISlher unit has received eadynoLllCaU'ort'to report for active duty Upon searching the data banks of the Department of Defense Manpower' DaCH::CA'n4Ar 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. 101( rt Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 File #: PKN32390 CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: VS. PETER N GEKAS 202 CONODOGUINET AVE CAMP HILL PA 17011 -4114 CERTIFICATE OF SERVICE A I hereby certify that on this _/,� I day of & z,7a— 20_,L3 I mailed a e true and correct copy of the foregoing praecipe for entry of judgmupon the party(s) or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: PETER N GEKAS 202 CONODOGUINET AVE CAMP HILL PA 17011 -4114 File #:PKN32390 COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION I 'COUNTY OF CUIMERLAW HEARING NOTICE Mag. Dist. No.: PLAINTIFF: NAME and ADDRESS 09 -3 -04 F CAPITAL ONE BANK USA RL MoJName: Hon. 425 EAGLE ROCK AVE. THOXAS A. PLACEY C/O PAUL J. ELB>ID[, ESQ. Add'—:104 S SPORTING HILL RD LROSELAND, NJ 07068 J MECHANICSBURG, PA vs. DEFENDANT: NAME and ADDRESS Te+epnone: (717) 761 -8230 17050 rGEKAS, PETER N. , z 202 CONODOGUINET AVENUE ? CA" HILL, PA 17011 -4114 s CAPITAL ONE BANK USA NA L J 425 EAGLE ROCK AVE. Docket No.: CV- 0000551 -08 C/O PAUL J. Mum, ESQ. Date Filed: 8/19/08 ROSELAND, NJ 07068 I A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 10/23/08 Place: DISTRICT COURT 09 -3 -04 104 S SPORTING HILL RD Time: 8 :45 AN IIMCHANICSSURG, PA 17050 717 -761 -6230 _.... . , OT eE TO DE k 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 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 judgment creditor to enter satisfaction. y NOTICE TO PLAINTIFF 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. AOPC 308B -05 DATE PRINTEDs 8119108 10 :05:28 AN r- COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT M291SIO l 0 4bict Number. PLAINTIFF: 09 -3 -04 Mm MW ADOUSS PAPITAL ONE BANK USA NA "'Q' ft": M0 "• Go Paul J. Klemm, Esquire Thomas A. Placey Nudelman, Nudelman & Ziering, P.C. AcWraaa 425 Eagle Rock Ave., Roseland, NJ 07068 244 South Sporting Hill Road VS. Mechanicsburg, PA 17050 ,DE FENDANT: ruin and ADDrMss T o t ep t m "•: (PETER N GEKAS —� 717/76] -8230 202 CONODOGUINET AVE CAMP HILL PA 17011-0114 r No.: ed: t�} A t� o 9 AMOUNT DATE PAID R � FILING COSTS $ � - POSTAGE $ SERVICE COSTS $ CONSTABLE ED. $ TOTAL 89.50 L1.1lL(L Pa.R.C.P.D.J. No. 208 sets forth those costs recoverable by the prevailing party. To THE DEFENDANT: The above named plaintiff (s) asks Judgment against you for ; 3 9.37 together with costs upon the following claim (Civil fines must Inc lude citation of the statute or or ordinance v Defendant owes Plaintiff the above referenced sum for: Breach of Contract on credit card account number 5178052470108651: Money due and owing on the 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. 1, Paul J. Klemm Esquire verify that the facts set forth in this complaint are true a orrect o the best of my knowledge, Information, and belief. This statement is made subject to the penalties of Section 4 4 of the C m e (18 PA. C.S. § 4904) related to unsworn falsification to authorities. Plaintiff's (signature of Plaintiff or Authorized Agent) Attorney: Paul J. Klemm. Esquire ID # 92125 Address: 425 Eagle Rock Avenue Telephone: _ 973-618 -0000 Roseland, NJ 27068 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 308A -05 CAPITAL ONE BANK IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA VS. DOCKET NO.: PETER N GEKAS 202 CONODOGUINET AVE CAMP HILL PA 17011 -4114 NOTICE OF JUDGEMENT OR ORDER TO: O Defendant ( ) Garnishee You are hereby notified pursuant to Pa. C.P. 236 that the following order of judgment was entered against you on: _day of _ , 20. () Judgment in the amount of $4,018.87 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 O ROT ONOY: By: vs - !t) PROTHONOTARY (OR DEPUTY)