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Home My WebLink About13-6204 Nudelman, Klemm, & Golub, P.C. Y() ( ) F -OF Irl �, Attorne s f or PKN12013 c.r 425 Eagle Rock Avenue - Suite 403 O THE P R O T H Q N Q TA r" tii Roseland, NJ 07068 (973) 618 -0000 [tel.] g (973) 618 -0647 [fax] 20 1 3 3 CT 21 PM 2: 5 CAPITAL ONE BANK CUMBERLAND C4UIN THE COURT OF COMMON PLEAS 15000 Capital One Drive PE CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA VS. DOCKET NO.: RANDI L SMITH 347 EAST WATER STREET Middletown PA 17057 TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFERIENTER JUDGMENTXNTRY 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), RANDI L SMITH, in the amount of $360.38, in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000708 -08, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $1,514.66 INTEREST (from December 11, 2008) $245.72 COSTS (Expended post judgment) $0.00 Less Payments /Adjustments made - $1,400.00 Total: $360.38 Nudelman, Klemm and Golub, P. Ey 9 � Z - Robert L. Baroska 3r Esquire P.A. ID # 306728 l- �q� ILP9 CAPITAL ONE BANK IN THE COURT OF COMMON PLEAS, 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA VS. DOCKET NO.: RANDI L SMITH 347 EAST WATER STREET Middletown PA 17057 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), RANDI L SMITH, is believed to be: 347 EAST WATER STREET Middletown PA 17057 ; 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 1 P 2013 Robert L. Baroska Y Esquire Attorney for Plaintiff File # PKN12013 CAPITAL ONE BANK IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA VS. DOCKET NO.: J'q y RANDI L SMITH 347 EAST WATER STREET Middletown PA 17057 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: 9 day of C+ , 20A ( ) Judgment in the amount of $360.38 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 OH OT By: PROTHONOTARY (OR DEPUTY) CAPITAL ONE BANK IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: vs. RANDI L SMITH 347 EAST WATER STREET Middletown PA 17057 CERTIFICATE OF SERVICE hereby certify that on this kday of 20 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: RANDI L SMITH 347 EAST WATER STREET Middletown PA 17057 File #:PKN12013 Y ' COMMONWEALTH OF PENNSYLVANIA 4 �J 1 3 CIVIL ACTION COUNTY OF CUMBERLAND ` HEARING NOTICE Map. Dist. No.: PLAINTIFF: NAME and ADDRESS 09 -3 -04 rCAPITAL ONE BANK USA NA 7 MDJName: Hun. 425 EAGLE ROCK AVE. APT /STE 403 THOMAS A. PLACEY C/O PAUL J. KLEMM, ESQ. Addre,:s: 1 04 S SPORTING HILL RD L R OSELAND, NJ 07068 J MECHANICSBURG, PA vs. DEFENDANT: NAME and ADDRESS 'leleplume 1717 f 761 -8230 17050 ( SMITH, RANDI L. � 52 N. OLD STONEHOUSE ROAD ATTORNEY FOR PLAINTIFF CARLISLE, PA 17015 PAUL J. KLEMM L J 425 EAGLE ROCK AVE. APT /STE 403 Docket No.: CV- 0000708 -08 NUDELMAN,NUDELMAN, ZIERING Date Filed: 10/15/08 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: 12/11/08 Place: DISTRICT COURT 09 -3 -04 104 S SPORTING HILL RD Time: 8:45 AM MECHANICSBURG, 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 set 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 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: 10/15/08 9:56:00 AM AOPC 3086 -05 COMMONWEALTH OF PENNSYLVANIA ` mCOUNTY OF: CUMBERLAND CIVIL COMPLAINT Megisteriai DistrirtNumber: PLAINTIFF: NAME and ADDRESS 09 -3 -04 (CAPITAL ONE BANK USA NA MDJ Name: Hon c/o Paul J. Klemm, Esquire Thomas A. Placey Nudelman, Nudelman & Ziering, P.C. Address: 425 Eagle Rock Ave., Roseland, NJ 07068 J 104 South Sporting Hill Road VS. Mechanicsburg, PA 17050 DEFENDANT NAME and ADDRESS Telephone: (RANDI L SMITH 717/761 -8230 52 N OLD STONEHOUSE RD CARLISLE PA 17015 --978 L / /►� Docket No.: C'� 400 r7Ovc� Date Filed- AMOUNT DATE PAID FILING COSTS $ 6 / 4A POSTAGE $ /a 1 SERVICE COSTS $ ! ! CONSTABLE ED. $ '� / !! TOTAL x75.00 i1LLR - 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 a gainst you for $ $1,439.66 together with costs upon the following claim (Civil tines must irilde citation of the statute or ordinance vio a e : Defendant owes Plaintiff the above referenced sum for: Breach of Contract on credit card account number 5178052604862041; 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 co ect to the best of my knowledge, information, and belief. This statement Is made subject to the penalties of Sectio 04 of a Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. 1— (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 30BA -05 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case M � Mag. Dist. No: MDJ- 09 -3 -04 Capital One Bank Usana MDJ Name: Honorable Paula P. Correal V Address: 5275 East Trindle Road Randi L. Smith Suite 110 Mechanicsburg, PA 17050 Telephone: 717- 697 -2201 Paul John Klemm, Esq. Docket No: MJ- 09304 -CV- 0000708 -2008 Nudelman Nudelman & Ziering Case Filed: 10/15/2008 425 Eagle Rock Ave Roseland, NJ 0700 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09304 -CV- 0000708 -2008 Capital One Bank Usana Randi L. Smith Default Judgment for Plaintiff 12/11/2008 Judgment Summary Participant Join Several Liability Individual Liability Amount Capital One Bank Usana $0.00 $0.00. $0.00 Randi L. Smith $0.00 $1,514.66 $1,514.66 Judgment Detail ( *Post Judgment) In the matter of Capital One Bank Usana vs. Randi L. Smith on 12/11/2008 the judgment was awarded as follows: Judgment Comoonent Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,439.66 $1,439.66 Costs $0.00 $75.00 $75.00 Grand Total: $1,514.66 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 JUDGMENTITRANSCRIPT 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 DISQstena GE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. do ? ,a �..0 Date District J udge certify that this is a true and correct copy of the recor o t ' L e rocee ings con fining he judgment Date Mag istrict Judge MDJS 315 Page 1 of 2 Printed: 07123/2013 8:57:40AM Capital One Bank Usana Docket No.: MJ- 09304 -CV- 0000708 -2008 V. �=';LED-OF ICL Randi L. Smith JF i Nt P ROTHONOTAR'i 2013 OCT 21 PM 2: 5 9 Participant List CUMBERLAND COUNTY PENNSYLVANIA Plaintiff(s) Capital One Bank Usana C/O Paul J. Klemm, Esq. 425 Eagle Rock Ave. Suite #403 Roseland, NJ 07068 \ Defendant(s) _ _ r Randi L. Smith, 52 N. Old Stonehouse Road Carlisle, PA 17015 Complainant's Attorney(s) Paul John Klemm, Esq. t Nudelman Nudelman & Ziering 425 Eagle Rock Ave Roseland, NJ r K MDJS 315 Page 2 of 2 Printed: 07/23/2013 8:57:40AM 8 Department of Defense Manpower Data Center Results as Ot :Oct -16 -2013 08:21:53 SCRA 3.0 Ruisuant to Servicememben Civil Relief Act Last Name: SMITH First Name: RANDI Middle Name: L Active Duty Status As Of: Oct -18 -2013 ...... '? t -- ;: {Nt AOh)le Qufy C�c�Ae'f)ve 17uty:Status pflta ,. t t �r 1 - t :. 'ServldeComponenl. ''! NA NA NA This response refleciS`itti3'_sidi A ueis' active dpfY si'atu @:be'sed on ihe:'AGtiJe'.�jhtty Date o .,.:..�, _.': ._: ._::; •..: �- an, patNelJ�nyv� min�SyAaYS +zlA�puaf�otystatas.datfl ,, t Acmre'L1q?y.$larr i]ate r AC hrA flsi<y Er1d43ara ' r $12tus $e vlomP4r ®rr7" '. NA t ' A i i�7o h :� NA This response reflects JOererthe indr'lduel left actroeAUly slef0s+htftiA G7i]ays preceding the Act7ve .D'uty Statue Dale -. ,,. " theMerirbar:' artl�s/ NerttnttW' asNavliQdvlai= uinnaCalt- UPZa�cuveUutyonAvdvafluNStatusLlats; `;' Orc�8rn7bfnicHfidn StarfAat& �CJrrderrVottpc�v�hE+td (aai� ,.> ' t ., ; yferus ={ , . ., SdNlce ., '" NA NA This response reflects whether dl� ,hrs/her and has rL ysd Qa1t� 6.6 . 1 . icQti0fi'to report for active duty Upon searching the data banks of the Department of Defense Manpower Daa'.Center,•tiased 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. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 File #: PKN12013 ROBERT L. BAROSKA, III, ESQUIRE NUDELMAN, KLEMM & GOLUB, P.C. 425 EAGLE ROCK AVENUE ROSELAND, NJ 07068 973-618-0000 ID #306728 HE PROT/10110 TA', 2014 SEP 25 PI; 2: G5 CUNSERL AND COUkrY PENIVSYLVA - naIFF ATTORNEY FOR PLA CAPITAL ONE BANK V. RANDI L SMITH CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 13-6204 Civil PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the Money Judgment in the above matter as satisfied against the above - captioned Defendant upon payment of your costs only. ..; SEP 2 3 2014 Date: Respectfully Submitted: NUDELMAN, KLEMM & GOLUB, P.C. Robert L. Baroska, III, Esquire 425 Eagle Rock Avenue Roseland, NJ 07068 (973) 618-0000 PKN12013 ROBERT L. BAROSKA, III, ESQUIRE NUDELMAN, KLEMM & GOLUB, P.C. 425 EAGLE ROCK AVENUE ROSELAND, NJ 07068 973-618-0000 ID #306728 FICE-0-01=1:1(; PROTHO,Y01,111. P 25 CU 6' ERC4N0 COO, '" ATTORNEY FOR PL- - /VA/iNTIFF CAPITAL ONE BANK V. RANDI L SMITH Plaintiff(s) Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 13-6204 Civil CERTIFICATE OF SERVICE I, Katherine Dieterle, hereby certify that a true and correct copy of the Plaintiff's Praecipe to Satisfy Judgment was served this date by first class U.S. Mail, postage prepaid, upon the following: RANDI L SMITH 347 EAST WATER STREET Middletown PA 17057 Date: Respectfully Submitted: NUDELMAN, KLEMM & GOLUB, P.C. 'or / (tie e ine Dieterle, Legal Assistant 25 le Rock Avenue Roseland, NJ 07068 (973) 618-0000 PKN12013