HomeMy WebLinkAbout14-2964 Nudelman,Klemm,&Golub,P.C.
Attomey(s)for Plaintiff(NN40208)
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
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VS. DOCKET NO. 3 ~ ,
LEONARD L MCLAUGHLIN n
2 COLGATE DRQ- = '
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CAMP HILL PA 17011-7622
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TO THE CUMBERLAND COUNTY PROTHONOTARY: -<
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), LEONARD L MCLAUGHLIN, in the amount of$3,623.39, in
accordance with the Magisterial District Court Judgment for money damages docket to
CV-0000169-09, a certified copy of which is being filed herewith. Damages are computed as
follows:
Amount of Judgment: $3,623.39
INTEREST(from June 5, 2009) $0.00
COSTS (Expended post judgment) $0.00
Less Payments/Adjustments made -$.00
Total: $3,623.39
Nudelman, Klemm and Golub,P.C.
By
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Robert L. Baroska 3`d,Esquire
P.A. ID # 306728
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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.:
LEONARD L MCLAUGHLIN
2 COLGATE DR
CAMP HILL PA 17011-7622
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), LEONARD L MCLAUGHLIN, is believed
to be: 2 COLGATE DR CAMP HILL PA 17011-7622 ; 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
MAY. 1 4p
Robert L. Baroska 3rd, Esquire
Attorney for Plaintiff
File# NN40208
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COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUNTY OF CUMBERLAND Case
Mag. Dist. No: MDJ-09-1-01 Capital One Bank (USA), N.A.
MDJ Name: Honorable Charles A. Clement Jr. V.
Address: 920 Linda Lane Leonard L Mc Laughlin
Camp Hill, PA 17011
Telephone: 717-737-3434
Capital One Bank(USA), N.A. Docket No: MJ-09101-CV-0000169-2009
Nudelman, Klemm & Golub Case Filed: 4/8/2009
425 Eagle Rock Ave Suite 403
Roseland, NJ 07068
Disposition Summary (cc-Cross complaint)
Docket No Plaintiff Defendant Disposition Disposition Date
MJ-09101-CV-0000169-2009 Capital One Bank(USA), N.A. Leonard L Mc Laughlin Default Judgment for Plaintiff 06/05/2009
Judgment Summary
Participant Joint/Several Liability Individual Liability Amount
Capital One Bank(USA), N.A. $0.00 $0.00 $0.00
Leonard L Mc Laughlin $0.00 $3,623.39 $3,623.39
Judgment Finding (*Post Judgment)
In the matter of Capital One Bank (USA), N.A. vs. Leonard L McLaughlin on MJ-09101-CV-0000169-2009, on 6/05/2009 the judgment
was awarded as follows:
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $3,070.70 $3,070.70
Interest $0.00 $613.59 $613.59
Attorney Fees $0.00 $387.44 $387.44
Costs $0.00 $159.25 $159.25
Grand Total: $3,623.39
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.
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6/5/2009
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.
4/14/2014 " Q � -
Date Magisterial District Judge
MDJS 315 Page 1 of 2 Printed:04/14/2014 12:32:12PM
Capital One Bank (USA), N.A. Docket No.: MJ-09101-CV-0000169-2009
v.
Leonard L McLaughlin
Participant List
Plaintiff(s)
Capital One Bank(USA), N.A.
Nudelman, Klemm&Golub
425 Eagle Rock Ave Suite 403
Roseland, NJ 07068
Defendant(s)
Leonard L Mc Laughlin
2 Colgate Drive
Camp Hill, PA 17011
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MDJS 315 Page 2 of 2 Printed:04/14/2014 12:32:12PM
Depardment of Defense Manpower Data Center Results W 01:Mey-14-201408:38:52 AM
SCRA 3.0
Status Repon
;:umuant to Sery cemefnbets Civil Relief Ace i
Last Name:MCLAUGHLIN
First Name:LEONARD
Middle Name:L
Active Duty Status As Of:May-14-2014
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This re nae reflects:h191adv tluals.,ectide duty statusbased an the A 4649 DUiy;tletus Date'
NA IVA W NA
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This res Dose mle wh fier(„$`'iiW VIOua11 h's4ier 6hN hes ei i d e9rlynot ticet dii to rapoM for active duly
Upon searching the data banks of the Department of Defense Manpower:Date Center,:tiasad 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.
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Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
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File#:NN40208
COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION
COUNTY OF: CMWERLAND HEARING NOTICE
May.Dist.No.: PLAINTIFF: NAME and ADDRESS
09-1-01 "CAPITAL ONE BANK USA NA 7
MDJ Name Hon. 425 EAGLE ROCK AVE
CHARLES A. CLEMENT, JR PAUL J KLEMM ESQ
address. 400 BRIDGE ST LROSELAND, NJ 07068 J
OLDS TOWNS COMMONS -SUITS 3 vs.
NEW CUMBERLAND, PA DEFENDANT: NAME and ADDRESS
Telephone: (717 ) 774-5989 17070 "MC LAUGHLIN, LEONARD L
2 COLGATE DRIVE
CAMP HILL, PA 17011
L J
CAPITAL ONE BANK USA NA
425 EAGLE ROCK AVE Docket No.: CV-0000169-09
PAUL J KLEMM ESQ Date Filed: 4/08/09
ROSELAND, NJ 07068 �Q
A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for:
Date: 5/08/09 Place: DISTRICT COURT 09-1-01
400 BRIDGE ST
Time: OLDS TOWNE COMMONS -SUITE 3
9:00 AN NEW 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(B)(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: 4/08/09 10:46:29 AM
AOPC 3088-05
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND CIVIL COMPLAINT
Magisterial District Number. PLAINTIFF: NAME and ADDRESs
09-1-01 Fc—APITAL ONE BANK(USA), N.A.
MDJ Nemo:Non, 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 ENDANT: NAME and ADDRESS
LEONARD L MCLAUGHLIN,
Telephone: 2 COLGATE DR
717/774-5989 A MP HILL PA 17011-7622 J
Docket No.: C O
Date Filed:
-g- o
AMOU T DATE PAID
FILING COSTS $
POSTAGE $ / !
SERVICE COSTS $ ! /
CONSTABLE ED. $
TOTAL $134.25
Pe.R.C.P.D.J.No.206 sets forth those costs recoverable by the prevailing party.
TO THE DEFENDANT:The above named plaintiff(sl asks judgment against you for$ $4,071.73 together with costs upon the following
claim(Civil fines must Include citation of the statute or ordinance violated):
Upon the insistance of the Defendant, Plaintiff issued Defendant a credit card and/or line of credit, account number
4305722150725433. Defendant owes Plaintiff the principal amount of$3,070.70, interest of$613.59,and attorneys fees of
$387.44. Breach of Contract on said account; Money due and owing on an account stated; Money due and owing on
an open book account; Reasonable value of goods sold and delivered and/or services rendered;and Unjust
enrichment.
1, Paul J. Klemm. Esquire verify that the facts set forth in this complaint are trueand—co—ririett to the best of my knowledge,
Information,and belief. This statement Is made subject to the penalties of Secti 904 of the C Imes Code(18 PA.C.S.§4904)
related to unswom falsification to authorities.
(Signature of Plaintiff or Authorized Agent)
Plaintiff's
Attorney: Paul J. Klemm, Esquire ID#92125 Address: 425 Eagle Rock Avenue
Telephone: 973-618-0000 Roseland, NJ 07068
IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT THE
ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO,
JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT.
If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you
intend-to assert at the hearing,you must file it on a complaint form at this office at least five(5)
days before the date set for the hearing.
If you are disabled and require a reasonable accommodation to gain access to the Magisterial
District Court and Its services,please contact the Magisterial District Court at the above
address or telephone number. We are unable to provide transportation.
AOPC 308A-05/NN40208
d
CAPITAL ONE BANK(USA),N.A. IN THE COURT OF COMMON PLEAS
15000 Capital One Drive CUMBERLAND COUNTY,
RICHMOND VA 23286 PENNSYLVANIA
VS. DOCKET NO. :
LEONARD L MCLAUGHLIN
2 COLGATE DR
CAMP HILL PA 17011-7622
NOTICE OF JUDGEMENT OR ORDER
TO: O Defendant
( ) Garnishee
You are hereby notified pursuant to Pa. R.C.P. 236 that the following order of judgment was
entered against you on: J(p day of , 20-1q.
( ) Judgment in the amount of3 6$ . 23.39,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 PROTHONOTARY:
, i
By:
PROTHONW