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HomeMy WebLinkAbout13-5896 Nudelman, Klemm, & Golub, P.C. Attorney(s) for Plaintiff (NN27183) 425 Eagle Rock Avenue - Suite 403 Roseland, NJ 07068 (973) 618 -0000 [tel.] (973) 618 -0647 [fax] CAPITAL ONE BANK (USA), N.A. IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA l vi vs. / DOCKET NO.: SABRINA E LANDAU 2423 HARVARD AVE CAMP HILL PA 17011 -5334 c ,, and � GOOD BO IE EALTH CLUB C cry C:) 2423 HARVA AVE CAMP HILL P 1 1 -5334 r O` p CD TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFERIENTER 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 (USA), N.A. in the above captioned matter. Kindly enter judgment, indexing the same as captioned above, in favor of the Plaintiff and against the Defendant(s), SABRINA E LANDAU , in the amount of $2,196.44, in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000420 -2008, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $2,196.44 INTEREST (from January 13, 2009) $0.00 COSTS (Expended post judgment) $0.00 Less Payments /Adjustments made -$.00 Total: $2,196.44 Nudelman, Klemm and Golub, P.C. P, z By Robert L. Baroska 3r Esquire Q V,,A &'3rl asa�c P.A. ID # 306728 CV 6 uuTS.I. 124 - lcLClo CAPITAL ONE BANK (USA), N.A. IN THE COURT OF 15000 Capital One Drive COMMON PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA VS. DOCKET NO.: J D q SABRINA E LANDAU 2423 HARVARD AVE CAMP HILL PA 17011 -5334 and > HA IES HEALT PA 170 34 VERIFICATION /AFFIDAVIT OF NON - MILITARY SERVICE The undersigned does hereby verify, subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unswom falsification to authorities, that the undersigned is the attorney for the Judgment Creditor, CAPITAL ONE BANK (USA), N.A.; 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), SABRINA E LANDAU is believed to be: 2423 HARVARD AVE CAMP HILL PA 17011 -5334 2423 HARVARD AVE CAMP HILL PA 17011 -5334; 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. OCT Q 7 20'13 yP Robert L. Baroska 3` Esquire Attorney for Plaintiff File # NN27183 CAPITAL ONE BANK (USA), N.A. IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA vs. DOCKET NO.: 1 SABRINA E LANDAU 2423 HARVARD AVE CAMP HILL PA 17011 -5334 and BOODIES HEALTH 2423, C �ILLPAI �-34 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: � day of C) C , 2019. ( ) Judgment in the amount of $2,196.44 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 P TH T XP By: PROTHONOTARY (OR DEPUTY) Department of Defense Manpower Data Center Results as of: Oct-07-2013 08:23:45 SCRA 3.0 Status Rep P mum t to Sery cememben Civil. Relief Act Last Name: LANDAU First Name: SABRINA Middle Name: Active Duty Status As Of: Oct -07 -2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA �t,�. j� _ , - ..— ,....; �i � No NA This response status based on fhe Acitve Duty;Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date +� '} y /{ �_�?. { y Service Component NA JIINA r+.:�'#i °No }' jl I NA M,- - �ti Z r n a This response reflects where 1114 Individual left ac8va tystatus:wi(hin in 36T days precedit!g the ,A ve Duty Status Data The Member or Hls/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component N,A� +'J.� �.`5ti.:.._ . r JNo;t� rF� NA This response reflects whether the Individual or hisRter unit has received to report for alive duty 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. �.r Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 CAPITAL ONE BANK (USA), N.A. IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: vs. SABRINA E LANDAU 2423 HARVARD AVE CAMP HILL PA 17011 -5334 and D BOODIES HEALT �2423 H L P CERTIFICATE OF SERVICE , hereby certify that on this � 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: SABRINA E LANDAU 2423 HARVARD AVE CAMP HILL PA 17011 -5334 and GOOD BOODIES HEALTH CLUB 2423 HARVARD AVE CAMP HILL PA 17011 -5334 File #:NN27183 - � COMMONWEALTH OF PENNSYLVANIA NN1a�i 3 .. CIVIL ACTION COUNTY OF CUMBERLAND HEARING NOTICE Mag. Dist. No.: PLAINTIFF: NAME and ADDRESS 09 -1 -02 FCAPITAL ONE BANK(USA)NA MDJName: Hon. 425 EAGLE ROCK AVE ROBERT V. MANLOVE NUDELMAN,NUDELMAN&ZIERING Address: 1 STATE ST LROSELAND, NJ 07068 J CAMP HILL, PA VS. DEFENDANT: NAME and ADDRESS Telephone: (717) 761 -0583 17011 -0000 [ LANDAU, SABRINA E 2423 HARVARD AVE CAMP HILL, PA 17011 -5334 C/O PAUL J KLEMM ESQ L J 425 EAGLE ROCK AVE Docket No.: CV- 0000420 -08 NUDELMAN,NUDELMAN&ZIERING Date Filed: 12/08/08 ROSELAND, NJ 07068 A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 1/13/09 Place: DISTRICT COURT 09 -1 -02 1901 STATE ST Time: 1:15 PM CAMP HILL, PA 17011 -0000 717 -761 -0583 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(13)(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. DATE PRINTED: 12/08/08 2:24:30 PM AOPC 3088 -05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Magisterial District Number. PI , A INTIFF• NAME and ADDRESS 09 -I -02 (CAPITAL ONE BANK (USA), N.A. MDJ Name: Hon. c/o Paul J. Klemm, Esquire Address Robert V. Manlove 42 Ea agle Rock Roseland, NJ 07068 I901 State Street VS. Camp Hilt, PA 17011 FENDANT: NAME and ADDRESS Telephone: SABRINA E LANDAU, 717/761 -0583 2423 HARVARD AVE L AMP HILL PA 17011 -5334 J [Date ocket No.: C�(- 4a o -0 8 Filed: f a AMOUNT DATE PAID .�- FILING COSTS $ S POSTAGE $ SERVICE COSTS $ 1 (6 (e7_ CONSTABLE ED. $ aS. dy TOTAL 1, /a► / T Pd.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 $ $2,091.27 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance v o a e Defendant owes Plaintiff the above referenced sum for: Breach of Contract on credit card account number 4 11 5072653052C95; 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. I, Paul J. Klemm Esquire verify that the facts set forth in this complaint are true an rec o the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 49 of the Cr' es Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. (Signature of Plaintiff or Authorized Agent) Plaintiff's Attorney: Paul J. Klemm, Esquire ID # 92125 Address: 425 Eagle Rock Avenue 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 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- 051NN27183 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND � � � - Case d Mag. Dist. No: MDJ- 09 -1 -02 Capital One Bank(Usa)na MDJ Name: Honorable Elizabeth S. Beckley V. Address: 1901 State Street Sabrina E Landau Camp Hill, PA 17011 Telephone: 717- 761 -0583 Capital One Bank(Usa)na Docket No: MJ- 09102 -CV- 0000420 -2008 Attn: C/O Paul J Klemm Esq Case Filed: 12/8/2008 425 Eagle Rock Ave Roseland, NJ 07068 Disposition Summary Docket No Plaintiff Defendant Disposition Disogsition Date MJ- 09102 -CV- 0000420 -2008 Capital One Bank(Usa)na Sabrina E Landau Default Judgment for Plaintiff 01/13/2009 Judgment Summary Participant Joint /Several Liability Individual Liability Amount Capital One Bank(Usa)na $0.00 $0.00 $0.00 Sabrina E Landau $0,00 $2,196.44 $2,196.44 Judgment Detail (*Post Judgment) In the matter of Capital One Bank(Usa)na vs. Sabrina E Landau on 1/13/2009 the judgment was awarded as follows: Judament Component Joint /Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,091.27 $2,091.27 Costs $0.00 $105.17 $105.17 Grand Total: $2,196.44 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK 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. M strict Da Judge certify that this is a true and correct copy of the record of the proceedingA the j ent. District Judge MDJS 315 Page 1 of 2 Printed: 08/13/2013 12 :47:47PM „ Capital One Bank(Usa)na Docket No.: MJ- 09102 -CV- 0000420 -2008 v. Sabrina E Landau Participant List s Plaintiff(s) Capital One Bank(Usa)na Attn: C/O Paul J Klemm Esq rr 425 Eagle Rock Ave Roseland, NJ 07068 ) Defendant(s) mac' CD c Sabrina E Landau G 2423 Harvard Ave 37 Camp Hill, PA 17011 -5334 sO Complainant's Attorney(s) Paul John Klemm, Esq. Nudelman Nudelman & Ziering 425 Eagle Rock Ave Roseland, NJ MDJS 315 Page 2 of 2 Printed: 08/13/2013 12:47:47PM