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Home My WebLink About13-6834 Nudelman, Klemm, & Golub, P.C. Attomey(s) for Plaintiff (NN20661) 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 VS. DOCKET NO.: ' J • �c>7 !/! SCOTT M GOTTHARD 15 S BALTIMORE AVE APT 101 MOUNT HOLLY SPRINGS PA -t 17065 -1333 � ' - fi t , ^� •, c TO THE CUMBERLAND COUNTY PROTHONOTARY: >C11 c, C- v c r� PRAECIPE TO TRANSFER/ENTER JUDGMENT/ENTRY OF APPEARANC 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), SCOTT M GOTTHARD, in the amount of $2,963.34, in accordance with the Magisterial District Court Judgment for money damages docket to CV- 0000532 -08, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $2,963.34 INTEREST (from February 24, 2009) $0.00 COSTS (Expended post judgment) $0.00 Less Payments /Adjustments made -$.00 Total: $2,963.34 Nudelman, Klemm and Golub, P.C. By xy Robert L. Baroska 3r Esquire P.A. ID # 306728 X31• `S�a �a gg3y$ Oct 1-k- 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.: SCOTT M GOTTHARD 15 S BALTIMORE AVE APT 101 MOUNT HOLLY SPRINGS PA 17065 -1333 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), SCOTT M GOTTHARD, is believed to be: 15 S BALTIMORE AVE APT 101 MOUNT HOLLY SPRINGS PA 17065 -1333 ; 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. Nov Robert L. Baroska 3r Esquire Attorney for Plaintiff File # NN20661 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.: SCOTT M GOTTHARD 15 S BALTIMORE AVE APT 101 MOUNT HOLLY SPRINGS PA 17065 -1333 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 MV , , 20. () Judgment in the amount of $2963.34 plus costs. ( ) Entry of Judgment of: ( ) Court Order ( ) Non -Pros ( ) Confession ( ) Default ( ) Garnishee ( ) Verdict ( ) Arbitration Award ( ) A copy of all documents filed with the Prothonotary in support of the within judgment are enclosed. If you have any questions concerning this notice please contact Plaintiff's counsel, Nudelman, Klemm, & Golub, P.C. at 973/618 -0000. BY ORDER OF PROTHO TA By: .� PROTHONOMY (OR DEPUTY) CAPITAL ONE BANK (USA), N.A. IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO.: VS. SCOTT M GOTTHARD 15 S BALTIMORE AVE APT 101 MOUNT HOLLY SPRINGS PA 17065 -1333 CERTIFICATE OF SERVICE -�G�� "� <a hereby certify that on this day of � 2013 I mailed a true and correct copy of the foregoing praecipe for entry ofjudgment upon the party(s) or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: SCOTT M GOTTHARD 15 S BALTIMORE AVE APT 101 MOUNT HOLLY SPRINGS PA 17065 -1333 File #:NN20661 i r Results as 01: Nov - 14-2013 05:42:40 Department of Defense Manpower Data Center SCRA 3.0 Last Name: GOTTHARD First Name: SCOTT Middle Name: M Active Duty Status As Of: Nov -14 -2013 '.`: Acn1!e S1ar3DatQ 1 c t t, AdrvQDltty �ndt)die a' r c r t satus t � rc > rrr ISerVtce'.Cb�lponant;' f NA NA .1 t17?,'0 :, NA This response reflect§ tt}s Nttlnhduals active duty sta7us;be'sad on tfie.AeroJa�pUty Date NA NA ., Acuve Dtiiy GtartDete ':` AdUVepiny End Data.:`t S�tys Sen+ICe�dthPorienY" This response reflects wh 4111e indiViduel left adrve dtity sJ$iu $rhntrli!'r 387.days preceding ilia %SC.Iive Status Date 7haMemberarks/NartJntlwasNo fledoiafutueCalr�tpYaflbvvebuiyonAatWe {iutyStatusRate Omer VbtArcAttdn 0et§ OYCerN o �cap�n E1d Det� Status SgroiceCdA porfeM NA NA This response reflects whether ihetriditndUiil bf hrsmer unit he recBved Qady: notifipij�bn`to report for acvve duty r Upon searching the data banks of the Department of Defense Manpower DaE6'b" ' r'i 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, A A kAft Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 File #: NN20661 COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION QUJNTY OF CUMBERLAND HEARING NOTICE Mag. DIM. No.: PLAINTIFF: NAME and ADDRESS 09 -3 -03 rCAPITAL ONE BANK MDJ Name: Hon. 425 EAGLE ROCK AVE SUSAN X. DAY ROSELAND, NJ 07068 Address: 2 29 MILL ST, BOX 167 J L MT. HOLLY SPRINGS, PA v5. DEFENDANT: NAME and ADDRESS Telephone: (717 ) 486 - 17065 f SCOTT MICHAE 15 S BALTIMORE AVE APT /STE 5 ATTORNEY FOR PLAINTIFF : MT. HOLLY SPRINGS, PA 17065 L J PAUL J. KLEMM 425 EAGLE ROCK Docket No.: CV- 0000532 -08 NUDELMAN NUDELMAN & ZIERI Date Filed: 12/31/06 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: 2/24/09 Place: DISTRICT COURT 09 -3 -03 229 MILL ST, BOX 167 Time: 2:00 PM MT. HOLLY SPRINGS, PA 17065 717 - 486 -7672 I NOTICE TO DEFENDANT It 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 Med 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: 12/31/08 8s20: AM AOPG 3088 -05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT .Msg1atulal1D1atdctNumber: PLAINTIFF NAME and ADDRESS 09 -3 -03 FCAPITAL ONE BANK (USA), N.A. T } MDJ Name Non. clo Paul J. Klemm, Esquire Susan K. Day Nudelman, Nudelman & Ziering, P.C. Address: 425 Eagle Rock Ave., Roseland, NJ 07068 _f 229 Mill Street VS. Mt. Holly Springs, PA 17065 DEFENDANT NAMEandADDRESS (SCOTT M GOTTHARD, Telephone. 15 S BALTIMORE AVE APT 5 717/486 -7672 MOUNT HOLLY SPRINGS PA 17065 -1333 L —� Docket No. C V - 5 32 -a 8 Date Filed: 4 z.- 5 X-<:� S AMOUNT DATE PAID FILING COSTS $ I J POSTAGE $ J ! SERVICE COSTS $ J CONSTABLE ED. $ J TOTAL $93.50 12J 311 O � Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintif(s) asks judgment against you for $ $ together with costs upon the following claim (Civil fines must include citation of the statute or ordinance vro a e Defendant owes Plaintiff the above referenced sum for Breach of Contract on credit card account number 5178052584273359; 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 jpd-0FMqt to the best of my knowledge, Information, and belief. This statement is made subject to the penalties of Sec tio 04 of the C mes Code (98 PA. C.S. § 4904) related to unworn falsification to authorities. (Signature of Plalrttlff or Authorized Agent) Plaintiffs 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 306A- 05/NN20661 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil x Case Mag. Dist. No: MDJ- 09 -3 -03 Capital One Bank MDJ Name: Honorable Susan K. Day V Address: 229 Mill Street Scott Michael Gotthard P.O. Box 167 Mount Holly Springs, PA 17065 Telephone: 717- 486 -7672 Capital One Bank Docket No: MJ- 09303 -CV- 0000532 -2008 Attn: C/O Paul J. Klemm, Es. Case Filed: 12/31/2008 425 Eagle Rock Ave Roseland, NJ 07068 Disposition Summary (cc -Cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09303 -CV- 0000532 -2008 Capital One Bank Scott Michael Gotthard Default Judgment for Plaintiff 02/24/2009 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank $0.00 $0.00 $0.00 , Scott Michael Gotthard $0.00 $2,963.34 $2,963.34 Judgment Finding ( * Post Judgment) In the matter of Capital One Bank vs. Scott Michael Gotthard on 2/24/2009 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,869.84 $2,869.84 Costs $0.00 $93.50 $93.50 Grand Total: $2,963.34 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, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date M isterial istrict Judge Susan K. Day i w i. certify that this is a true and correct copy of e record of the procee ing ontaimng a judgment.. Date v / Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 10/03/2013 10:26:41AM Capital One Bank Docket No.: MJ- 09303 -CV- 0000532 -2008 V. Scott Michael Gotthard i Participant List Plaintiff(s) Capital One Bank Attn: C/O Paul J. Klemm, Es. 425 Eagle Rock Ave Roseland, NJ 07068 Defendant(s) Scott Michael Gotthard 15 S Baltimore Ave Apt #5 Mount Holly Springs, PA 17065 CompiainihYs Attorn4y(s) ? G --� -o co rn Paul John Klemm, Esq. - ri Nudelman Nudelman & Ziering CD 425 Eagle Rock Ave Roseland, NJ t� -:r-- 20 tU ra . T t • t 4 MDJS 315 Page 2 of 2 Printed: 10/03/2013 10:26:41AM