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HomeMy WebLinkAbout14-3066 Nudelman,Klemm,&Golub,P.C. Attorney(s)for Plaintiff(NN38310) 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. : ,3 HEATHER HURST 1� �' -- � 210 HILL ST APT 5o MT HOLLY SPRINGS PA 17065-1332 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), HEATHER HURST, in the amount of$3,249.21, in accordance with the Magisterial District Court Judgment for money damages docket to CV-0000120-09, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $3,249.21 INTEREST(from May 26, 2009) $0.00 COSTS (Expended post judgment) $0.00 Less Payments/Adjustments made -$.00 Total: $3,249.21 Nudelman, Klemm and Golub, By Aobert L. Baroska 3`d, Esquire P.A. ID # 306728 f3/. as�d ��A(02 q 3 ��fi �yw 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.: HEATHER HURST 210 HILL ST APT 5 MT HOLLY SPRINGS PA 17065-1332 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), HEATHER HURST, is believed to be: 210 HILL ST APT 5 MT HOLLY SPRINGS PA 17065-1332 ; 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). Nudelm`an, Klemm and Golub, P.C. MAY 19 2014 l Robert L. Baroska 3rd, Esquire Attorney for Plaintiff File# NN38310 3o(b 6 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND - Case Mag. Dist. No: MDJ-09-2-02 Capital One Bank C/Opaul J. Klemm MDJ Name: Honorable Jessica Brewbaker V. Address: 18 North Hanover Street, Suite 106 Heather Hurst Business Central Building Carlisle, PA 17013 Telephone: 717-240-6564 Capital One Bank C/Opaul J. Klemm Docket No: MJ-09202-CV-0000120-2009 Nudelman, Nudelman &Zier Case Filed: 4/14/2009 425 Eagle Rock Ave Roseland, NJ 07068 Disposition Summary (cc Docket No Plaintiff Defendant Disposition Disposition Date MJ-09202-CV-0000120-2009 Capital One Bank C/Opaul J. Heather Hurst Default Judgment for Plaintiff 05/26/2009 Klemm Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank C/Opaul J. Klemm $0.00 $0.00 $0.00 Heather Hurst $0.00 $3,249.21 $3,249.21 Judgment Findin g g ('Post Judgment) In the matter of Capital One Bank C/Opaul J. Klemm vs. Heather Hurst on MJ-09202-CV-0000120-2009, on 5/26/2009 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $3,156.71 $3,156.71 Costs $0.00 $92.50 $92.50 Grand Total: $3,249.21 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. 4-*A t Date terial District Judge Jessica Brewbaker '1-2� certify that this is a true and correct copy of the cord o the proceeding u gment. t � contai ng t e l l (4_ Date Magisitrio District Judge MDJS 315 Page 1 of 2 Printed: 11/13/2013 10:11:10AM Capital One Bank C/Opaul J. Klemm Docket No.: MJ-09202-CV-0000120-2009 V. Heather Hurst Participant List Plaintiff(s) Capital One Bank C/Opaul J. Klemm Nudelman, Nudelman&Zier 425 Eagle Rock Ave Roseland, NJ 07068 Defendant(s) Heather Hurst 410 1st Street03 s Carlisle, PA 17013-1801 Complainant's Attorney(s) Paul John Klemm, Esq. Nudelman Nudelman&Ziering c 425 Eagle Rock Ave Roseland, NJ MDJS 315 Page 2 of 2 Printed: 11/13/2013 10:11:10AM CAPITAL ONE BANK(USA),N.A. IN THE COURT OF COMMON PLEAS 15000 Capital One Drive CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA out VS. DOCKET NO. : (A - Sou b HEATHER HURST 210 HILL ST APT 5 MT HOLLY SPRINGS PA 17065-1332 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: a day of f A , 20141 . cly ( ) Judgment in the amount of3 2$ 49.21, 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 PROT NOT Y: By: g- PROTHONOTARY(OR DEPUTY) Department of Defense Manpower Data Center Arians es M:Mey19.201404'39:11 AM SORA 3.9 f Stattag Repoft Pursuatit 1a S-micemembers Civil Relief Act r' Last Name:HURST First Name:HEATHER Middle Name: Active Duty Status As Of:May-19-2014 NA } , �t NaNA mds re se m6w`i frtle'Ir;5 Ws'.�.4Je:d4'sI.iu W6 dd do tha Ad W D(A;Slaws Dole NA j;,l�'1._ 4 :(.jd <�4`'' NA IV ri; �:iit.o::,,n'_.. '? Stasis Deb TN.,r nse relletls v"d1dV�'19 iMiuiduel left earvo Eul sltiti4.wdHh 36y,'tle .eceai`'ttre"Adlva ' - r t ' ::.DMsr:N4l�te(lon Si'anDate f. ,, Ordor.NoiiAcaron`Ei1d,D0te :::Status .?t,s .r5orviee NA NA ilse—p,.reAacb rdbhe'r(tt$'i0dv('Eiml.p hromar iinti'Itbilraaonrod e- otdical,an b, n 1a aCW0 duty Upon searching the data banks of the Department of Defense Manpower,Date CenjOr basad ori the Information that you provided,the above is the status of the individual on the active status date as to all branches of the Uniformed Services(Army,Na Marine duty ( y Navy, Corps.Air Force,NOAH,Pudic Health,and Coast Guard).This status includes information on a Servlcemember or his/her unit receiving notification of future orders to report for Active Duty. - 4 ot 7404 ,- Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 File#:NN38310 CAPITAL ONE BANK(USA),N.A. IN THE COURT OF COMMON 15000 Capital One Drive PLEAS,CUMBERLAND RICHMOND VA 23286 COUNTY,PENNSYLVANIA DOCKET NO. : ' 3*4p vs. HEATHER HURST 210 HILL ST APT 5 MT HOLLY SPRINGS PA 17065-1332 CERTIFICATE OF SERVICE ereby certify that on this day of 20sI mailed a true and correct copy of the foregoing praecipe for entry ofjudgment upon e"party(s)or representative(s)named below and in the manner indicated: Via first class mail postage prepaid: HEATHER HURST 210 HILL ST APT 5 MT HOLLY SPRINGS PA 17065-1332 File#:NN38310 COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION COUNTY OF: CUMBERLAND HEARING NOTICE Mag.Dist.No.: PLAINTIFF: NAME and ADDRESS 09-2-02 rCAPITAL ONE BANK C/O PAUL J. KLMIX-1 MDJName: Hon. 425 EAGLE ROCK AVE JESSICA BASNBAKER NUDELMAN, NUDBLKAN & ZIER Add'en: 18 N BANOVZR ST STS 106 LROSELAND, NJ 07068 J CARLISLE, PA vs. DEFENDANT: NAME and ADDRESS Telephone: (717 ) 240-6564 17013 rSURST, HEATHER 410 IST STREET CARLISLE, PA 17013-1801 CAPITAL ONE BANK C/O PAUL J. KLEKK L J 425 EAGLE ROCK AVE Docket No.: CV-0000120-09 NUDELII< N, MMELI[AN A ZIER Date Filed: 4/14/09 ROSELAND, NJ 07065 Ila A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 5/26/09 Place: DISTRICT COURT 09-2-02 18 N SANOVER ST STE 106 Time: 9:00 Alli CARLISLE, PA 17013 717-240-6564 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. AOPC 3088-05 DATE PRINTED: 4/14/09 11:38:15 AM 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Maglaterial DhtAel Number. PLAINTIFF: NAME and ADDRESS 09-2-02 [CAPITAL ONE BANK(USA), N.A. MDJ Name:Hon. c/o Paul J. Klemm, Esquire Jessica E. Brewbaker Nudelrban, Nudelman&Ziering, P.C. Addraaa: 425 Eagle Rock Ave., Roseland, NJ 07068 _J 18 North Hanover SAreet VS. Carlisle, PA 17013 DE�FENpANT: NAME and ADDRESS Telephone: 1HEATiHER HURST, 717/240-6564 4101$T ST CARLISLE PA 17013-1801 L _I Docket1No.: Date Filled: Filled: " ,Li .� AMOUNT DATE PAID FILING COSTS $ &P.-So ! / POSTAGE $ ID. SERVICE COSTS $ CONSTABLE ED. $ TOTAL $92.50 / / Pa.R.C.P.D.J.No.206 sets forth those costs recoverable by the prevailing party.; TO THE DEFENDANT:The above named plaintiffs)asks judgment against you for$ $3.156.71 together with costs upon the following claim(Civil fines must Include citation of the s4tute or ordinance violated): Upon the insistance of the Defendant, Plaintiff issued Defendant a credit card and/or line of credit, account number 4862362619290177. Defendant owes Plaintiff the principal amountlof$2,318.40, interest of$533.04,and attorneys fees of $305.27. 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 dells ered and/or services rendered; and Unjust enrichment. 1, Paul J. Klemm. Esquire verify that the facts set forth in this complaint are true and qoffeetto the best of my knowledge, information,and belief. This statement is made subject to the perjalties of Section 490 f the Cri es Code(18 PA.C.S. §4904) related to unsworn falsification to authorities. (Sig ntiff 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, YQU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HARING 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/NN38310