HomeMy WebLinkAbout14-3946 Nudelman,Klemm,&Golub,P.C.
Attorney(s)for Plaintiff(NN48429)
425 Eagle Rock Avenue-Suite 403 OFr I L ED-
Roseland,NJ 07068 T"'E P�001r[
(973)618-0000[tel.] ONO TAj-"'y
(973)618-0647[fax]
2014 JUL -7 Phl 3- 4 3
CAPITAL ONE BANKqq�k� IN THE COURT OF COMMON PLEAS
15000 Capital One Drive EMVqA";'D COW4TY
!'y S1`C1 A Iq I A, CUMBERLAND COUNTY,
RICHMOND VA 23286 PENNSYLVANIA
VS. DOCKET NO. :
TATIANA M THOMAS
525 CHERRY CT
CARLISLE PA 17013-1891
TO THE CUMBERLAND COUNTY PROTHONOTARY:
PRAECIPE TO TRANSFER/ENTER JUDGMENT/ENTRY OF APPEARANCE
Please enter Robert L. Baroska, 3d, 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), TATIANA M THOMAS, in the amount of$6,477.97, in
accordance with the Magisterial District Court Judgment for money damages docket to
CV-0000201-09, a certified copy of which is being filed herewith. Damages are computed as
follows:
Amount of Judgment: $6,477.97
INTEREST(from August 11, 2009) $0.00
COSTS (Expended post judgment) $0.00
Less Payments/Adjustments made -$.00
Total: $6,477.97
Nudelman, Klemm and Golub, P.C.
B 4 .2. dA_5k "
Robert L. Baroska 3`d, Esquire
P.A. ID # 306728 01sfid Oi
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._Department of Defense Manpower Data Center Resulffi as of:JU-03.201406:23:09 AM
SCRA 3.0
St s Report
Purs»aftt to:S±brvieemern Civil ReliefAct
Last Name:THOMAS
First Name: TATIANA
Middle Name: M
Active Duty Status As Of: Jul-03-2014
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This responserellads',ther7ndimduels`ecliv`eAut stetus6lisedort1heAc$veOUt:�,_-
••..�. : .,. LehAWe:Dilt Wdhtn367,Ds s o1 A`oriyB DU1y;St'aiils Date„ ""
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This responserellectswtisie'ifi9'individuelleftaclivedJl.'sti76 X*days precedj�',`thci'X DUI Status Date
_.,..,.__ _,�.,_.,..._711u,f�Aemba£..or,HirJ}iat.';'LnI1.We8:NOUired of a Flnure.Call;11 toAct va_,Du on Acfiya_Duty Status Oale, ``�'
'} Orders<lo''fisc'd40nSlerl`.b"a1e _ .,.,t ,,:OrderNoAfit�fionEndrpela '` t. , .. ;tStatu9 _ ? ` f S$ivlce�'otn' etit,
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This response reflects whetheriR@'i�tlividuaY::dr hisrti'Ar:iu{ithas`leceiveC,esn Ji`6lfifi;atioiilo r rt for active duty -
': J'r'!'r�ai•?i;:r:::-��..p:r.,p::q.r;,-..i'::_..,.:cb;^Y:rr`;'�r.-.
Upon searching the data banks of the Department of Defense Manpoviwe'r'tJataGenter}baseii'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 Uniformetl`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
DepartmeM,of Defense-Manpower Data Center
4800 Marc Center Drive,Suite 04E25
Arlington,VA 22350
File#: NN48429
P
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
.The
System(DEERS)database which Is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
Individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http//www.defenselink.mil/faq/pis/PC09SLOR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAH Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for Induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: XBC44DAOKOD8U70
File#: NN48429
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.:
TATIANA M THOMAS
525 CHERRY CT
CARLISLE PA 17013-1891
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), TATIANA M THOMAS, is believed to
be: 525 CHERRY CT CARLISLE PA 17013-1891 ; 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.
JUL
Robert L. Baroska 3`d, Esquire
Attorney for Plaintiff
File# NN48429
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. : )q ,
TATIANA M THOMAS
525 CHERRY CT
CARLISLE PA 17013-1891
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: -7 day of 20 1Y.
( ) Judgment in the amount of6$ ,477.97, 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:
By:
PROTHO Y)
CAPITAL ONE BANK(USA),N.A. IN THE COURT OF COMMON
15000 Capital One Drive PLEAS, CUMBERLAND
RICHMOND VA 23286 COUNTY, PENNSYLVANIA
DOCKET NO. : J i " ✓� `
vs.
TATIANA M THOMAS
525 CHERRY CT
CARLISLE PA 17013-1891
CERTIFICATE OF SERVICE
I, ereby certify that on this�' day of 20 , I mailed a
true and correct co of the oregoing praecipe for entry of judgment pon party(s 01r
pY g
representative(s) named below and in the manner indicated:
Via first class mail postage prepaid:
TATIANA M THOMAS
525 CHERRY CT
CARLISLE PA 17013-1891
File#:NN48429
COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUNTY OF CUMBERLAND - Case
Mag. Dist. No: MDJ-09-2-02 Capital One Bank C/Opaul Klemm
MDJ Name: Honorable Jessica Brewbaker V.
Address: 18 North Hanover Street, Suite 106 Tatiana M Thomas
Business Central Building
Carlisle, PA 17013
Telephone: 717-240-6564
Capital One Bank C/Opaul Klemm Docket No: MJ-09202-CV-0000201-2009
Nudelman,nudelman&ziering Case Filed: 6/29/2009
425 Eagle Rock Ave ;.
Roseland, NJ 07068 t V
M , :
G)>
Disposition Summary (cc-Cross Complaint) C) - CDC-.z
c�
Docket No Plaintiff Defendant Disposition Dimosizi Date
MJ-09202-CV-0000201-2009 Capital One Bank C/Opaul Tatiana M Thomas Judgment for Plaintiff 08%1/2009
Klemm
Judgment Summary
Participant Joint/Several Liability Individual Liability Amount
Capital One Bank C/Opaul Klemm $0.00 $0.00 $0.00
Tatiana M Thomas $0.00 $6,477.97 $6,477.97
Judgment Finding ("Post Judgment)
In the matter of Capital One Bank C/Opaul Klemm vs. Tatiana M Thomas on MJ-09202-CV-0000201-2009, on 8/11/2009 the judgment
was awarded as follows:
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $6,347.47 $6,347.47
Costs $0.00 $130.50 $130.50
Grand Total: $6,477.97
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. A
4*A
e.
t s'
Date 666 Magisterial District Judge Jessica Brewbaker _ -
I certify that this is a true and correct copy of the record of the procee in,s c ntaining the judgment.
Date Oagiterial District Judge
MDJS 315 Page 1 of 2 Printed:04!24/2014 4:40:18PM
COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION
COUNTY OF. CUMBERLAND HEARING NOTICE
Mag.Dist.No.: PLAINTIFF: NAME and ADDRESS
09-2-02 (CAPITAL ONE BANS C/O PAUL KLBMtIt<
MDJ Name: Hon. 425 EAGLE ROCS AVE
JESSICA BREMAKER NUDELMAN,NUDELXhN&ZIERING
Address: 18 N HANOVER ST STE 106 LROSELAND, NJ 07068 J
CARLISLE, PA vs.
DEFENDANT: NAME and ADDRESS
Telephone: (717 ) 240-6564 17013 rTHOMAS, TATIANA K
525 CHERRY CT
ATTORNEY FOR PLAINTIFF CARLISLE, PA 17013-1891
PAUL J. KLE1101 L J
425 EAGLE ROCK Docket No.: CV-0000201-09
NUDELMAN NUDELMAN A ZIERI Date Filed: 6/29/09
ROSELAND, NJ 07068
I
A civil complaint has been filed against you in the above captioned case.A hearing has been set in this matter for:
Date: 8/11/09 Place: DISTRICT COURT 09-2-02
18 N HANOVER ST STE 106
Time: 9s00 AM CARLISLE, PA 17013
I
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(6)(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: 7/01/09 11:49:28 AM
AOPC 30813.05