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Home My WebLink About14-2819 a j Nudelman,Klemm,&Golub,P.C. Attorneys)for Plaintiff(NN40321) 425 Eagle Rock Avenue-Suite 403 Roseland,N3 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. : SABOOR A MOHMAND k 4020 LISBURN RD MECHANICSBURG PA 17055-6704 -4 ` �`` 6 TO THE CUMBERLAND COUNTY PROTHONOTARY: p PRAECIPE TO TRANSFERIENTER JUDGMENTIENTRY OF APPEARANCE Please enter Robert L. Baroska, 3"d, 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), SABOOR A MOHMAND, in the amount of$1,063.05, in accordance with the Magisterial District Court Judgment for money damages docket to CV-0000174-09, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment, $1,063.05 INTEREST(from May 13, 2009) $0.00 COSTS (Expended post judgment) $0.00 Less Payments/Adjustments made -$,00 Total: $1,063.05 I Nudelman, Klemm and Golub, P.C. By Robert L. Baroska 3rd,Esquire P.A. ID # 306728 N �C, i. Im 4! �� COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-1-01 Capital One Bank USA MDJ Name: Honorable Charles A. Clement Jr. V. Address: 920 Linda Lane Saboor A Mohmand Camp Hill, PA 17011 Telephone: 717-737-3434 Capital One Bank USA Docket No: MJ-09101-CV-0000174-2009 Attn:paul Klemm Esq Case Filed: 4/13/2009 425 Eagle Rock Ave Roseland, NJ 07068 Disposition Summary (cc-Cross Complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-09101-CV-0000174-2009 Capital One Bank USA Saboor A Mohmand Default Judgment for Plaintiff 05/13/2009 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank USA $0.00 $0.00 $0.00 Saboor A Mohmand $0.00 $1,063.05 $1,063.05 Judgment Finding (*Post Judgment) In the matter of Capital One Bank USA vs. Saboor A Mohmand on MJ-09101-CV-0000174-2009, on 5/13/2009 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $815.78 $815.78 Interest $0.00 $396.36 $396.36 Attorney Fees $0.00 $160.52 $160.52 Costs $0.00 $80.75 $80.75 Grand Total: $1,063.05 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. 5/13/2009 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. 11/122013 Date Magisterial District Judge ' MDJS 315 Page 1 of 2 Printed:11/12/2013 1:11:12PM Capital One Bank USA Docket No.: MJ-09101-CV-0000174-2009 v. Saboor A Mohmand - Participant List Plaintiff(s) Capital One Bank USA T_ Attn:paul Klemm Esq 425 Eagle Rock Ave, Roseland, NJ 07068 " Defendant(s) ` Saboor A Mohmand - 4020 Lisburn Road .v'r- Mechanicsburg, PN I7055-6704 • V � '� L J T, i) - r y D-) !d I y CD { ' J rj c ti i k MDJS 315 Page 2 of 2 Printed: 11/12/2013 1:11:12PM COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION COUNTY OF: CUMBERLAND HEARING NOTICE Mag.Dist.No.: PLAINTIFF: NAME and ADDRESS 09-1-01 FCAPITAL ONE BANK USA � MDJName: Hon, 425 EAGLE ROCK AVE CSARLES A. CLEMENT, JR ATTN:PAUL KLEMM ESQ Address: 400 BRIDGE ST LROSELAND, Na 07068 J OLDS TOWNS COMMONS -SUITE 3 vs. NEW CUMBERLAND, PA DEFENDANT: NAME and ADDRESS Telephone: (717) 774-5989 17070 rMOBMAND, SABOOR A 4020 LISBURN ROAD MECHANICSBURG, PA 17055-6704 L J CAPITAL ONE BANK USA 425 EAGLE ROCK AVE Docket No.: CV-0000174-09 ATTN:PAUL KLEMM SSQ Date Filed: 4/13/09 ROSELAND, NJ 07068 1 A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 5/13/09 Place: DISTRICT COURT 09-1-01 400 BRIDGE ST Time: OLDS TOWNE COMMONS -SUITE 3 9:00 AN NEN CUMBERLAND, 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(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: 4/13/09 16:11:31 PM AOPC 30$13-05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF- CUMBERLAND CIVIL COMPLAINT Magisterlal Diablet Number: PLAINTIFF: NAME and ADDRESS 09-1-01 [CAPITAL ONE BANK(USA), N.A. MDJ Name:Hon. c/o Paul J. Klemm, Esquire Charles A.Clement,Jr. Nudelman, Nudelman &Ziering, P.C. Address: 425 Eagle Rock Ave., Roseland, NJ 07068 400 Bridge Street,Suite 3 VS. New Cumberland,PA 17070 pEFENDANT: NAME and ADDRESS ISABOOR A MOHMAND, Telephone: 4020 LISBURN RD 717/774-5989 M CHANICSBURG PA 17055-6704 Docket No.: _f 1 q- Date Filed: AMOUNT DATE PAID eJ FILING $-� I I POSTAGE GE $ ! ! SERVICE COSTS $ ! ! CONSTABLE ED. $ I ! TOTAL $80.75 ! ! Pa.R.C.P.D.J.No.206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT:The above named plalntiff(s asks judgment aggainst you for$ $1,372.66 together with costs upon the following claim(Civil fines must InVude citation of the statute or ordinance v o a e : Upon the insistance of the Defendant, Plaintiff issued Defendant a credit card and/or line of credit, account number 4121742513438534. Defendant owes Plaintiff the principal amount of$815.78, interest of$396.36,and attorneys fees of $160.52. Breach of Contract on said account; Money due and owing on an 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 a and cor ect to the best of my knowledge, information,and belief. This statement_is made subject to the penalties of Sec on 4904 of th Crimes Code(18 PA.C.S.§4904) related to unsworn falsification to authorities. v (Signature of PiainUff 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-05/NN40321 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.: SABOOR A MOHMAND 4020 LISBURN RD MECHANICSBURG PA 17055-6704 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), SABOOR A MOHMAND, is believed to be: 4020 LISBURN RD MECHANICSBURG PA 17055-6704 ; 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. MAY 0 5 2014 ' 67 - Robert L. Baroska 3", Esquire Attorney for Plaintiff i File# NN40321 t I I Department of Defense Manpower Data Center Results as of:May-05-2014 08:38:07 AM SCRA 3.0 s Status Bert Pursuant to Servicememben Civil Relief tact. Last Name: MOHMAND First Name: SABOOR Middle Name: A Active Duty Status As Of: May-05-2014 On Active Duty On Active Duty Status Date Active Duty Start Dale Active Duty End Date Status Service Component NA NA� I�:'I - t_i_ .� � No�� NA irY h - r IJ-11'.r ';t r r r Qed . -v- �,..r This response re0ects`the Individuals'active du status based on the Acture Du Status Date Leff Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date �.,, Status Service Component NA t11iNA �"i=.t3c .i�-_A#'c1' -No �Y i.J�� NA This response reflects where'lhe Ind vidual left active du4`status within 367 days precedin'g the Active&ty Status Date 1 tr• II,�(J!j The Member or His/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 NA �:NA1�'+.�� .E 'r'•:No NA This response reflects whether the indvid�ual or hisRrer unit has received eady'notifiratlon to report for active du '�i Upon searching the data banks of the Department of Defense Manpower Data Center,based",n 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. 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. SABOOR A MOHMAND 4020 LISBURN RD MECHANICSBURG PA 17055-6704 CERTIFICATE OF SERVICE V�h I hereby certify that on this day of qX4,jI mailed a true and correct copy of the foregoing praecipe for entry of judgment po - party s) or representative(s)named below and in the manner indicated: Via first class mail postage prepaid: SABOOR A MOHMAND 4020 LISBURN RD MECHANICSBURG PA 17055-6704 File#:NN40321 I i I I I