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Home My WebLink About13-6833 Nudelman, Klemm, & Golub, P.C.'�' Attorney(s) for Plaintiff (NN24731) { i #. �� i ,4 425 Eagle Rock Avenue - Suite 403 Roseland, NJ 07068 gg NOV �. �1 (973) 618 -0000 ftel.] 281 V 1 P M 2: O L (973) 618 -0647 [fax] CUMBERLAND COUNTY CAPITAL ONE BANK (USA), N.A. P E N N S Y LVAN I'AHE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA VS. DOCKET NO.: , 3` to 93) C'U DYLANN GEYER 2519 DATE WAY APT D LEXINGTON PARK MD 20653 TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFERIENTER 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 (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), DYLANN GEYER, in the amount of $1,493.50, in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000666 -08, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $1,493.50 INTEREST (from March 12, 2009) $0.00 COSTS (Expended post judgment) $0.00 Less Payments /Adjustments made -$.00 Total: $1,493.50 Nudelman, Klemm and Golub, P.C. By I < Z' O'� Robert L. Baroska 3r Esquire P.A. ID # 306728 c� �so�� 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.: �� LP DYLANN GEYER 2519 DATE WAY APT D LEXINGTON PARK MD 20653 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 (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), DYLANN GEYER, is believed to be: 2519 DATE WAY APT D LEXINGTON PARK MD 20653 ; 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.0 _ L NOV 1 2013 1 Robert L. Baroska 3` Esquire Attorney for Plaintiff File # NN24731 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.: 3 DYLANN GEYER 2519 DATE WAY APT D LEXINGTON PARK MD 20653 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: 1_?: day of Np� , , 20 ( ) Judgment in the amount of $1,493.50 plus costs. ( ) Entry of Judgment of: ( ) Court Order ( ) Non -Pros ( ) Confession ( ) Default ( ) Garnishee ( ) Verdict ( ) Arbitration Award ( ) A copy of all documents filed with the Prothonotary in support of the within judgment are enclosed. If you have any questions concerning this notice please contact Plaintiff s counsel, Nudelman, Klemm, & Golub, P.C. at 973/618 -0000. BY ORDER OF PR HO A toj B PROTHONOTARY (OR DEPUTY) CAPITAL ONE BANK (USA), N.A. IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: VS. DYLANN GEYER 2519 DATE WAY APT D LEXINGTON PARK MD 20653 CERTIFICATE OF SERVICE I e e, hereby certify that on this < day of 0 20 mailed a true and correct copy of the foregoing praecipe for entry of judgment upon the party(s) or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: DYLANN GEYER 2519 DATE WAY APT D LEXINGTON PARK MD 20653 File #:NN24731 Results as of: Nov - 142013 05:42:38 Department of Defense Manpower Data Center SCRA 3.0 stave :kf: Flunwant to Serviceinemben- Civil Relief Act Last Name: GEYER First Name: DYLANN Middle Name: Active Duty Status As Of: Nov -14 -2013 Nam f5r ne}rS� Qmy Ci j ilot)ve quit' Saws p�,e Aeuva:Duff S art DdiP .? ActNe biny Ead D1e ,' 6tetus Serv1Pe.0 4� ponent NA NA NA This response retlegl5 the rhtlr>nduals active status ba'sad on iha AGtwe pUty ; Status Date - NA A NA r r Lan-ACINe putg w�min 367 flltyS ¢i Ac1Ng Duty St�tUS 0g7a � ': 7+ctNe OntY$ tart pate: .+ ; AcUVe Duty Enn �1atd r } $iatus $erVlCa�¢mPOnenfi This response reflects nNdual left aoti" 1 st {u §mgt(Lr) 367ideys preceding ihe'AClive: DLty Status Date The Merrtber 'orHis/H8rflrniWasNoniortofa Putties Ca11 Wp ioAdlrve Duty.on Ac11va putq Staters gaffe ' QrderNOttlfcafi�inStl�i7' f CF�derNot {q�4y�hEttdQ6f$ ` ,; �tatU's - Sotbice - NA IVA r,.., :. til¢ NA This response reflects wlhetndivtEluiil of hrsFtter unit has received 8a11y"WU ga80n'to report for active duty hether� Upon searching the data banks of the Department of Defense Manpower'136 Cerxter;.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. t Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 File #: NN24731 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -1 -01 Capital One Bank MDJ Name: Honorable Charles A. Clement Jr. V Address: 920 Linda Lane Dylann Geyer Camp Hill, PA 17011 Telephone: 717- 737 -3434 Capital One Bank Docket No: MJ-091 01 -CV-0000666-2008 c/o Robert L. Baroska, III, Esq. Case Filed: 12/29/2008 425 Eagle Rock Avenue Roseland, PA 07068 Disposition Summary (cc -Cross Complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-091 01 -CV-0000666-2008 Capital One Bank Dylann Geyer Default Judgment for Plaintiff 03/12/2009 Judgment Summary - -- - - - _. Participant Joint/Several Liability Individual Liability Amount Capital One Bank $0.00 $0.00 $0.00 Dylann Geyer $0.00 $1,493.50 $1,493.50 Judgment Finding ( "Post Judgment) In the matter of Capital One Bank vs. Dylann Geyer on 3/12/2009 the judgment was awarded as follows: Judgment Component JoinVSeveral Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,389.75 $1,389.75 Costs $0.00 $103.75 $103.75 Grand Total: $1,493.50 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 k REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES OR OTHERWISE COMPLIES WITH THE JUDGMENT. 3/12/2009. Date Magisterial District Judge Charles A. Clement Jr. certify that this is a true and correct copy of the record of the proceedings containing the judgment. 9/30/2013 CA&A�& Date Magisterial District Judge ' MDJS 315 Page 1 of 2 Printed: 09/30/2013 12:31:13PM Capital One Bank Docket No.: MJ- 09101 -CV- 0000666 -2008 V. Dylann Geyer Participant List Plaintiff(s) P Capital One Bank c/o Robert L. Baroska, III, Esq. 425 Eagle Rock Avenue G, t"' Roseland, PA 07068 - S :. Defendant(s) (�p Dylann Geyer 347 9th St - y New Cumberland, PA 17070 Complainant's Attorney(s) - ' Paul John Klemm, Esq. Nudelman Nudelman & Ziering 425 Eagle Rock Ave Roseland, NJ s i MDJS 315 Page 2 of 2 Printed: 09/30/2013 12:31:13PM COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION ��73 COUNTY OF CIBMERLAHD HEARING NOTICE Mag. Dist. No.: PLAINTIFF: NAME and ADDRESS 09 -1 -01 rCAPITAL ONE BANK MDJ Name: Hon. 425 ]i'iA�ie LX ROCK AV8 CRARLES A. CL IM JR C/O PAUL KLZM[, 8SQ Address: 400 BRIDGE ST LQOSBLAW, PA 17068 J OLDS TOti KX COMMONS -SUITS 3 VS. NEOF CUMBERLAND, PA DEFENDANT: NAME and ADDRESS Telephone: ( 717 ) 774 -5989 17070 ro SYSR, DYLAHN 347 9TE ST NEW CUMBERLAND, PA 17070 CAPITAL ONE BANK L J 425 EAGLE ROCK AVE Docket No.: CV- 0000666 -08 C/O PAUL ELEM, ESQ Date Filed: 12/29/08 ROSSLAND, PA 17068 A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 2/13/09 Place: DISTRICT COURT 09 -1 -01 400 BRIDGE ST Time: OLDS TONNS COMMONS -SUITE 3 10 AN MIX CUIEBERLAHD, PA 17070 717 - 774 -5989 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. DATE PRINTED s 12/31/08 1:0205 Pit[ AOPC 3088 -05 COMMONWEALTH OF PENNSYLVANIA ,COUNTY OF: CUMBERLAND CIVIL COMPLAINT MapisteAd Diemet Number: PLAINTIFF NAME and ADDRESS 09 -1 -01 CAPITAL ONE BANK (USA), N.A. �} MDJName:Non. c/o Paul J. Klemm, Esquire Charles A. Clement, Jr. Nudelman, Nudelman & Ziering, P.C. Adore..; 425 Eagle Rock Ave., Roseland, NJ 07068 _J 400 Bridge Street, Suite 3 VS. New Cumberland, PA 17070 DEFENDANT: NAME and ADDRESS Telephone: FD GEYER, 717/774 -5989 347 9TH ST NEW CUMBERLAND PA 17070 -1305 L J . Docket No.: CV_0000666-08 Date Filed: 12/31/2008 i AMOUNT DATE PAID FILING COSTS $ 69 19 i 11 / f1R POSTAGE $ 9.75 1 2 / 31 / 0 8 SERVICE COSTS $ CONSTABLE ED. $ TOTAL $78.75 1 ! 1 ms g Pa.R.C.P.D.J. No. 208 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiffs) asks judgment against you for $ $ 1, 389-75 together with costs upon the following claim (Civil fines must Include citatlon of the statute or ordinance v o a : Defendant owes Plaintiff the above referenced sum for Breach of Contract on credit card account number 4862362321302906; 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, P @ul J. Klemm. Esquire verify that the facts set forth in this complaint are true an t to the best of my knowledge, Information, and belief. This statement is made subject to the penalties of Section 4 of the rimes Code (18 PA. C.S. §4904) related to unsworn falsification to authorities. (Signature of plaintiff or Authorized Agent) Plaintiff's Attomey. 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 -0UNN24731