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Home My WebLink About14-3763 Nudelman,Klemm,&Golub,P.C. Attorney(s)for Plaintiff(NN42940) 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 .Y� TINA M WRIGHT 45 SCRAFFORD ST SHIPPENSBURG PA 17257-1727 TO THE CUMBERLAND COUNTY PROTHONOTARY: PRAECIPE TO TRANSFERIENTER JUDGMENT/ENTRY 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), TINA M WRIGHT, in the amount of$1,513.55, in accordance with the Magisterial District Court Judgment for money damages docket to CV-0000164-09, a certified copy of which is being filed herewith. Damages are computed as follows: x: 7 Amount of Judgment: $1,513.55 0 �_. INTEREST (from July 15, 2009) $0.00 COSTS (Expended post judgment) $0.00 'carrj CD Less Payments/Adjustments made -$.00 CD C N.) < { Total: $1,513.55 Nudelman, Klemm and Golub, P.C. Ey .� Robert L. Baroska 3`d, Esquire �� I P.A. ID # 306728 ��I a 0)'J 1 e All) 1y- 3703 COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT COUNTY OF: CUMBERLAND CIVIL CASE Mag.Dist.No.: PLAINTIFF: NAME and ADDRESS 09-3-01 FCAPITAL ONE BANK (USA) N.A MDJName: Hon. 425 EAGLE ROCK AVE APT/STE 403 HAROLD E. BENDER ROSELAND, NJ 07068 Address: 35 W ORANGE ST L J SHIPPENSBURG, PA VS. DEFENDANT: NAME and ADDRESS Telephone: (717 ) 532-7676 17257-0361 Fw-RIGHT, TINA MARIE 45 SCRAFFORD ST SHIPPENSBURG, PA 17257 HAROLD E. BENDER L J 35 N ORANGE ST Docket No.: CV-0000164-09 SHIPPENSBURG, PA 17257-0361 Date Filed: 6/15/09 4 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF (Date of Judgment) 7/15/09 ® Judgment was entered for: (Name) CAPITAL ONE BANS (USA) N.A Judgment was entered against: (Name) WRIGHT, TINA MARIE in the amount of$ 1,513.55— Amount ,513.5Amount of Judgment is 1,432.55 ❑ Defendants are jointly and severally liable. Judgment Costs - • $ 81.00 F-1Damageswill be assessed on Date &Time Interest on Judgment $ .00 Attorney Fees •00 This case dismissed without prejudice. Total $ '1,513.55 ❑ Amount of Judgment Subject to Attachment/42 Pa.C.S. §8127 Post Judgment Credits $ $ Post Judgment Costs $ Portion of Judgment for physical damages arising out of residential lease$ Certified Judgment Total $ 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 THE 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,1F-.THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS,ALL FURTHER eFIOCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTE=RIAL-DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS,ANYONE INTERESTED IN THCmJ'l�b,GMENT MAY.FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT(EBTOR PAYS IN.FULL, SETTLES,OR OTHERWISE COMPLIES WITH THE JUDGMENT. tV CJn r - —. �C-> a. C- rV . C: Date , Q,coc/1 ��— , Magisterial District Judge I certify that this is a true and correct copy of the record of the proceedings containing the Judgment. Date , Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315-07 DATE PRINTED: 7/15/09 2:17:00 PM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Magisterial District Number IPtAINTIFF* NAME and ADDRESS 09-3-01 CAPITAL ONE BANK(USA), N.A. c/o Paul J. Klemm, Esquire MDJName:Mon. Nudelman, Nudelman &Ziering, P.C. Harold E. Bender 425 Eagle Rock Ave., Roseland, NJ 07068 VS. Address: FEN DANT: NAME and ADDRESS 35 West Orange Street �NA M WRIGHT, Shippensburg, PA 17257 45 SCRAFFORD ST 45 SCRAFFORD ST Telephone: 717/532-7676 6IPPENSBURG PA 17257-1727 Docket No.:CV_ Date Filed: AMO TE PAID FILING COSTS $ I/s/OF POSTAGE $ SERVICE COSTS $ CONSTABLE ED. $ TOTAL $81.00 i Pa.R.C.P.D,J.No.206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT:The above named plaintiff(sasks judgment against you for$ $1,432.56 together with costs upon the following claim(Civil fines must incl'ude citation of the statute or ordinance vio a e : Upon the insistance of the Defendant, Plaintiff issued Defendant a credit card and/or line of credit, account number 5178057223885331. Defendant owes Plaintiff the principal amount of$992.01, interest of$277.02,and attorneys fees of $163.52. Breach of Contract on said account; Money due and owing on an account stated; Money due and owing on an open book account; Reasonable value of goods sold and delivered and/or services rendered; and Unjust enrichment. I, Paul J. Klemm, Esquire verify that the facts set forth in this complaint are true d correct to the st of my knowledge, Information,and belief. This statement Is made subject to the penalties of Sectio 904 of the Crimes Co a(18 PA.C.S.§4904) related to unswom falsification to authorities. (Signature of Plaintiff or Authorized.Agent) Plaintiff's Attorney. Paul J. Klemm, Esouire ID#92125 Address: 425 Eagle Rock Avenue Telephone: 973-618-0000 Roseland NJ 07068 HE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five(5) days before the date set for the hearing. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services,please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 308A-051NN42940 Department bf Defense Manpower Data Center ROSUhs wof:Jun-23-201404:27:24 AM SCRA 3.0 lsfafti.5.R'ptlrt Pursuant to S'en cemernbets Civil Rolief Act Last Name:WRIGHT First Name:TINA Middle Name:M Active Duty Status As Of:Jun-23-2014 >:': ,+.' :' ;:: -•::P. ,.,::o Aaoe Dinvon carve ovi'Staws Dere '.:' -Atnye Du 'StedOBle ;.::'Aarve Du� ste 61eiUs Servicebom orletlt r NA NA This response reflects Hje:tn0 duels.eclid9 duly status based on the Addle Duly;Sletus Date A$irve DuNSls.i-:D91e ..<Aarva Duly Erid'Det S7eos _SerJtceC m onem .. . . .... NA .::SNA -No •1::i NA This response retleas where I ii indi idual lell ea'rve duly Stetu9 Fhlll}ii 36T-days p—Mi I r ngthe AciveF,D;ny Slates Dale r „�7heMa bar:o�H 6Mer.Unit YJss NonLed ofe:fufWa�&II U,jd ACs�o Du on�AoeveDUly Sta1u89ate Drdef:fJ01Alc91 on$tail;Dete :'brdac Noll#cetion.End Dete '.�5taiu8 S9rB C'9(,'oy(1 orlBnt a NA NA '�' NA This response reflects whathe 1hC'Iht vidUel.or hisRlar nn has retie Vied Beflyhdtilf061oti'lo re on lot arrive duly Upon searching the data banks of the Department of Defense Manpoweir:DefQCertec,basAd or the informal on 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,NOAH,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. Xh -N IF Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4600 Mark Center Drive,Suite 04E25 Arlington,VA 22350 File#:NN42940 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.: TINA M WRIGHT 45 SCRAFFORD ST SHIPPENSBURG PA 17257-1727 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), TINA M WRIGHT, is believed to be: 45 SCRAFFORD ST 45 SCRAFFORD ST SHIPPENSBURG PA 17257-1727 ; 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. JUN 2 3 2014 Robert L. Baroska Yd, Esquire Attorney for Plaintiff File# NN42940 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. TINA M WRIGHT 45 SCRAFFORD ST SHIPPENSBURG PA 17257-1727 CERTIFICATE OF SERVICE I, , hereby certify that on this d"a �of �0 L I mailed a Y true and correct copy of the foregoing praecipe for entry of judgmen upon the party( or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: TINA M WRIGHT 45 SCRAFFORD ST SHIPPENSBURG PA 17257-1727 File#:NN42940 COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION COUNTY OF. CUMBERLAND HEARING NOTICE Mag.Dist.No.; PLAINTIFF: NAME and ADDRESS 09-3-01 FCAPITAL ONE BARB (USA) N.A MDJName: Hon. 425 EAGLE ROCS AVE APT/STB 403 H�IROLD E. ZZWER ROSELAND, NJ 07068 Address; 35 W ORANGE ST SBIPP$NSBURG, PA L J VS. DEFENDANT: NAME and ADDRESS Telephone: (717 ) 532-7676 17257-0361 FWRIGHT, TINA MARIE 45 SCRAFFORD ST ATTORNEY FOR PLAINTIFF : SHIPPENSBORG, PA 17257 L J PAUL J. SLEM1111 425 EAGLE ROCS Docket No.: CV-0000164-09 NUDELMAN NUDELMAN A ZIERI Date Filed: 6/15/09 ROSELAND, NJ 07068 Ila A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 7/15/09 Place: DISTRICT COURT 09-3-01 35 N ORANGE ST Time: 2:00 PM SHIPPBNSBURG, PA 17257-0361 717-532-7676 i 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. i We are unable to provide transportation. DATE PRINTED: 6/15/09 15:10:35 PM AOPC 3088-05 a . 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. : - 5,�--- TINA M WRIGHT 45 SCRAFFORD ST SHIPPENSBURG PA 17257-1727 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: d?'$Iay of_)UUI& , 201_$ ( ) Judgment in the amount of$1,513.55, 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 973/61870000. BY ORDER OF PR HO AR By: PROT TARY (OR DEPUTY)