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Home My WebLink About13-3961 r 1 Nudelman, Klemm, & Golub, P.C. Attorneys) for Plaintiff (PKN04888) 425 Eagle Rock Avenue - Suite 403 Roseland, NJ 07068 (973) 618 -0000 [tel.] (973) 618 -0647 [fax] s �u CAPITAL ONE BANK C � IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA VS. DOCKET NO.: SHERRY A NAILOR 239 STONEHOUSE RD CARLISLE PA 17013 TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFER/ENTER JUDGMENTIENTRY OF 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), SHERRY A NAILOR, in the amount of $1,484.54, in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000181 -08, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $1,484.54 Less Payments /Adjustments made -$.00 Total: $1,484.54 Nudelman, Klemm and Golub, P.C. By q Robert L. Baroska 3` Esquire P.A. ID # 306728 C tAA� 0 Lh 6193? CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive COMMON PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA vs. DOCKET NO.: SHERRY A NAILOR 239 STONEHOUSE RD CARLISLE PA 17013 VERIFICATION /AFFIDAVIT OF NON - MILITARY SERVICE The undersigned does hereby verify, subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities, that the undersigned is the attorney for the Judgment Creditor, CAPITAL ONE BANK; with a mailing address of c/o Nudelman, Klemm and Golub, P.C., 425 Eagle Rock Ave. - Suite 403, Roseland NJ 07068; and that the last known address of the Judgment Debtor(s), SHERRY A NAILOR, is believed to be: 239 STONEHOUSE RD CARLISLE PA 17013 ; and that the Judgment is valid, enforceable and un satisf an ed, d that the facts set forth in the foregoing Praecipe are true and correct to the best of the undersigned's knowledge, information and belief. The undersigned, being duly sworn according to law, deposes and says that to the best of his knowledge information, and belief the above captioned Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Service Members Relief Act, 50 App. U.S.C. § 501 et. seq. (amended in 2004). Nudelman, Klemm and Golub, P.C. JUL 0 5 2013 I�Z Robert L. Baroska 3r Esquire Attorney for Plaintiff File # PKN04888 Department of Defense Manpower Data Center Results as Of: Ju9-05 -2013 08:45'07 SCRA 3.0 Last Name: NAILOR First Name: SHERRY Middle Name: A Active Duty Status As Of: Jul -05 -2013 prt Act ve puty tSn Aolne puty StaWs Date Actwe tn;ty Start Data . :: ActNe Duty end pate ' :. Status ;r NA NA NA "' Sernce Componeht, This response reflects iha thtlividuals apwe'Cuty status!ba'sed on fhaAGtive'DUtgStafus Date LeitAcfivaputyWahin367Da �otAcuaeputyStarQe,Date Y ..,.;, Actnle CStlfy -$tart Date,. , •'.� AdllvefJUty Ehdtyarp.- 't - ::: NA - . ; -_ SerolceCgmponent t NA No NA This response reflects where ihe�indwrduel left egrve duly slglus+wthm:67 days preceding iheAclrva.Duty Status Date 7tte Membebr Wis/Her {A6n Was Nonlied ofa Palace Calf Wp to/1cLve pufy on Act[ve putt' Status pate' Order NotAtcahon Stan Date .Order NoltficaLilh End paie ` NA seroiceComponem r 4N6, - Thisres p ons erellectswhetherlhemdrvldual :orN . s/rleruhd has received 4ady no911Ca4on`to report for active duty Upon searching the data banks of the Department of Defense Manpowei DaEY`anteF; based on the information that ou the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Fo NOAA, Pu the status and of Coast Guard). This status includes information on a Service member or his/her unit bl c 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. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 File #: PKN04888 The Defense Manl5ower Data Center (DMDC) is an organization of the Department of Defense (DOD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for'military medical care and other eligibility systems. The DOD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: h ttpY/ www. defenselink .mil/faq /Pis/PC09SLOR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Tifie 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 63EFKBC9601 FDCO File #: PKN04888 I CAPITAL ONE BANK IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA VS. DOCKET NO.: SHERRY A NAILOR 239 STONEHOUSE RD CARLISLE PA 17013 NOTICE OF JUDGEMENT OR ORDER TO: () Defendant O Garnishee You are hereby notified pursuant to Pa R.C.P. 236 that the following order of judgment was entered against you on: L day of l , 20], ( ) Judgment in the amount of $1,484.54, 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 PR ON TARY own ,'D B PROT ARY (OR DEPUTY) CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: VS. SHERRY A NAILOR 239 STONEHOUSE RD CARLISLE PA 17013 CERTIFICATE OF SERVICE I hereby certify that on this r day of 20 �3 I mailed a true and correct copy of the foregoing praecipe for entry of judgme t upon he party(s) or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: SHERRY A NAILOR 239 STONEHOUSE RD CARLISLE PA 17013 File #:PKN04888 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND - �� Case Mag. Dist. No: MDJ- 09 -3 -02 Nudelman Nudelman &ziering MDJ Name: Honorable Vivian Cohick V Address: 55 Penn Drive Sherry A Nailor Newville, PA 17241 Telephone: 717- 776 -3187 Paul John Klemm, Esq. Docket No: MJ- 09302 -CV- 0000181 -2008 Nudelman Nudelman & Ziering Case Filed: 10/13/2008 425 Eagle Rock Ave Roseland, NJ Disposition Summary _ Docket No Plaintiff Defendant Disposition Disposition Date MJ 09302 - CV - 0000181 - 2008 Nudelman Nudelman &ziering Sherry A Nailor Default Judgment for Plaintiff 11/18/2008 Judgment Summary Particioant Joint/Several Liability Individual Liability Amoun Nudelman Nudelman &ziering $0.00 $0.00 $0.00 Sherry A Nailor $0.00 $1,484.54 $1,484.54 Judgment Detail ( *Post Judgment) In the matter of Nudelman Nudelman &ziering vs. Sherry A Nailor on 11/18/2008 the judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,415.54 $1,415.54 Costs $0.00 $69.00 $69.00 Grand Total: $1,484.54 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, SETTLE OR OTHERWISE COMPLIES WITH THE JUDGMENT. ,,uh ,gyp 8- P O O? Date Magisterial District Judge Vivian Cohick certify that this is a true and correct copy of the record of the proceedings containing the judgment. S - a9- -9 o 13 Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 05/28/2013 2:32:48PM 4 Nudelman Nudelman &ziering Docket No.: MJ- 09302 -CV- 0000181 -2008 V. Sherry A Nailor Participant List Plaintiff(s) ti..i Nudelman Nudelman &ziering ^�r 425 Eagle Rock Ave Suite #403 Roseland, NJ 07068 Defendants)r Sherry A Nailor t' p 239 Stonehouse Road � Cn =� r Carlisle, PA 17013 D --- ` "- Complainant's Attorney(s)` Paul John Klemm, Esq. Nudelman Nudelman & Ziering 425 Eagle Rock Ave Roseland, NJ MDJS 315 Page 2 of 2 Printed: 05/28/2013 2:32:48PM COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION PMKE COUNTY OF CUMBICRLAND HEARING NOTICE Mag. Dist. No.: PLAINTIFF: NAME and ADDRESS 09 - -02 r NUDELMAN NUDELMAN 4 ZIERING MDJName: Hon. 425 EAGLE ROCK AVE APT /STE 403 VIVIAN COHICK ROSELAND, NJ 07068 Address: PO BOX 155 L J 27 at' BIG SPRING AVE VS. NMVILLE, PA DEFENDANT: NAME and ADDRESS Telephone: (717 ) 776 -3187 17241 rNAILOR, SHERRY A i. 239 STONEHOUSE ROAD ATTORNEY FOR PLAINTIFF CARLISLE, PA 17013 PAUL J. KLEMM L J l 425 EAGLE ROCK Docket No.: CV- 0000181 -08 NVDELMAN NUDELMAN & ZIERI Date Filed: 10/13/08 ROSELAND, Na 07068 A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 11/18/08 Place: DISTRICT COURT 09 -3 -02 PO BOX 155 Time: 27 N BIG SPRING AVE 10:45 AM NEWVILLE, PA 17241 717 - 776 -3187 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 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. 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 3088 -05 DATE PRINTED: 10/13/08 12:52 :40 PM COMMONWEALTH OF PENNSYLVANIA CIVIL COMPLAINT COUNTY OF: CUMBERLAND Magisterial Dletdot Number: PLAINTIFF NAME and ADDRESS 09 -3 -02 FCAPITAL ONE BANK USA NA c/o Paul J. Klemm, Esquire MDJ Name: Non. Nudelman, Nudelman & Ziering, P.C. Vivian J. Cohick q25 Eagle Rock Ave., Roseland, NJ 07068 �/ Address: s. 27 West Big Spring Avenue DEFENDANT: NAME and ADDRESS Newvilie, PA 17241 MERRY A NAILOR Telephone: 239 STONEHOUSE RD 717/776 -3187 CARLISLE PA 17013 L_ Docket No.: ( 61 Q$ Date Filed: OUNT DATE PAID FILING COSTS $ (/d - L-�e `3 16� POSTAGE $ L� SERVICE COSTS $ �— CONSTABLE ED. $ - TOTAL 79.00 — Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The acbov^einarm m ai ed pl ustf must asks citation o the g atute oyordinanee v o a e5.54 together with costs upon the following Defendant owes Plaintiff the above referenced sum for: Breach of Contract on credit card account number 4862362392427558; 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. my knowledge, I, Paul l and belief. i This statement is made subject to the p Section 490 f the C mes Code (18 C S § 4904) informatto related to unsworn falsification to authorities. l (Signature of Plaintiff or Authorized Agent) Plaintiff Address: 425 Ea41e Rock Avenue Attorney: Paul J Klemm Esquire ID # 92125 Telephone. 973 - 618 -0000 Roseland NJ 07068 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TEL EPHON MAY E3E ENTERED AGAINST YOU BY DEFA R A HE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO JUDG 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