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
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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.:
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
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Last Name:HURST
First Name:HEATHER
Middle Name:
Active Duty Status As Of:May-19-2014
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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