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Home My WebLink About14-4409 Nudelman,Klemm,&Golub,P.C. Attorney(s)for Plaintiff(NN47391) I L E D-O F'F J C E 425 Eagle Rock Avenue-Suite 403 OF 7, pt-t o ��aki Roseland,NJ 07068 �/, ' ' (973)618-0000[tel.] JUL(973)618-0647[fax] 01 U 2 8 PH 1: 36 CAPITAL ONE BANK(USA)N L Yip C0UNTT Y THE COURT OF COMMON PLEAS . 15000 Capital One Drive A N1 1 A CUMBERLAND COUNTY, RICHMOND VA 23286 PENNSYLVANIA ' C' VS. DOCKET NO. . I KEITH L SMITH 512 POPLAR CHURCH RD CAMP HILL PA 17011-1832 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), KEITH L SMITH, in the amount of$1,516.84, in accordance with the Magisterial District Court Judgment for money damages docket to CV-0000225-09, a certified copy of which is being filed herewith. Damages are computed as follows: Amount of Judgment: $1,516.84 INTEREST (from September 1, 2009) $0.00 COSTS (Expended post judgment) $0.00 Less Payments/Adjustments made -$.00 Total: $1,516.84 Nudelman, Klemm and Golub, P.0 By Robert L. Baroska 3`1, Esquire P.A. ID # 306728 �� dJ a 1�1�ied Wo r Department of Defense Manpower Data Center Results as of Jul-25.2014 0035:41 AM SCRA 3.0 tac Report Last Name: SMITH First Name: KEITH Middle Name: L Active Duty Status As Of: Jul-25-2014 Ac1lve Duty 5lxft_O ate" .. Active Duty End Dater ..:j, .. ,Status .. Service%Com ohera' �':.'; NA NA .rT1b NA This response reflects the individuals"' ive duty status based onthewclive TSiity.Status Date -�:. -0811 Active DUt.:wilh�F7 367�{'3x S Ul A6iiv2{)uT Status.Dsle ..; '. Acnve DuiyStart,Date:.�- ActNe D,iny End Daie;�� ,:Sixtus Sennce�Com neni`; - NANA :No, - NA This response reflects wWire o,individual lett active dlil`: txtusbYilhln:36�d s'"recedm� the,Aellve.+�Duly Status Date 7he.Meriitier briisFHer'-hint was 7Vo''iied of f'lure•Cell!U'io A Lvx 0-i.an AatroelDut Si�tusi0ate ^ �Arder tVotdicatton Start bats ,-;r ,..0?der NabllceUon�nq-0aie - -„ -� � ,'Sixtws;, ,- Sarvice Com,onenl`' NA +NA t - -;.No NA This response relocis whetl�r The individual or his/n'er unh has redeived Bxrl notdreatitln o're ort for active duty 1 , Upon searching the data banks of the Department of Defense Mian"pbwer 0"t, nt&;based 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 Servi (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 Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 File #: NN47391 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting 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 sec,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:httpJ/www.defenselink.mil/faq/pis/PC09SLDR.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(NOAA 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: HB11ZBOD400AU40 File #: NN47391 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.: I KEITH L SMITH 512 POPLAR CHURCH RD CAMP HILL PA 17011-1832 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), KEITH L SMITH, is believed to be: 512 POPLAR CHURCH RD CAMP HILL PA 17011-1832 ; 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. Z Z:��o Robert L. Baroska 3`d, Esquire Attorney for Plaintiff File# NN47391 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. KEITH L SMITH 512 POPLAR CHURCH RD CAMP HILL PA 17011-1832 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: o?gday of , 201. 61 ( ) Judgment in the amount of$1,516.84, 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 PRO ON R By: , PROTHONOTARY (OR DEPUTY) CAPITAL ONE BANK (USA),N.A. IN THE COURT OF COMMON 15000 Capital One Drive PLEAS, CUMBERLAND RICHMOND VA 23286 COUNTY, PENNSYLVANIA DOCKET NO. : �� 1 vs. KEITH L SMITH 512 POPLAR CHURCH RD CAMP HILL PA 17011-1832 CERTIFICATE OF SERVICE V-h I, S 1A , hereby certify that on this tg,,:jday of 20 , I mailed a true and correct copy of the foregoing praecipe for entry of judgment pont party( ) or representative(s) named below and in the manner indicated: Via first class mail postage prepaid: KEITH L SMITH 512 POPLAR CHURCH RD CAMP HILL PA 17011-1832 File#:NN47391 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND -- Case Mag. Dist. No: MDJ-09-1-02 Capital One Bank (Usa) Na MDJ Name: Honorable Elizabeth S. Beckley V. Address: 1901 State Street Keith L Smith Camp Hill, PA 17011 Telephone: 717-761-0583 Paul John Klemm, Esq. Docket No: MJ-09102-CV-0000225-2009 Nudelman Nudelman &Ziering Case Filed: 7/8/2009 425 Eagle Rock Ave Roseland, NJ 07068 Disposition Summary (cc-Cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-09102-CV-0000225-2009 Capital One Bank(Usa)Na Keith L Smith Default Judgment for Plaintiff 09/01/2009 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank(Usa)Na $0.00 $0.00 $0.00 Keith L Smith $0.00 $1,516.84 $1,516.84 Judgment Finding (*PostJudgment) Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amoun Civil Judgment $0.00 $1,413.14 $1,413.14 Costs $0.00 $103.70 $103.70 Grand Total: $1,516.84 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. (?/1 A Date giste i i ict u ge certify that this is a true and correct copy of the record of the proceedings contai g e ju gme t. Date i r rict Judge MDJS 315 Page 1 of 2 Printed:05/01/2014 11:22:59AM Capital One Bank (Usa) Na Docket No.: MJ-09102-CV-0000225-2009 V. Keith L Smith Participant List Plaintiff(s) Capital One Bank(Usa) Na Attn: C/O Paul J Klemm Esq 425 Eagle Rock Ave Roseland, NJ 07068 Defendant(s) Keith L Smith 512 Poplar Church Rd Camp Hill, PA 17011-1832 _ -i Complainant's Attorney(s) rCJ Paul John Klemm, Esq. ) C)` ' Nudelman Nudelman &Ziering 425 Eagle Rock Ave Roseland, NJ 07068 " c=: MDJS 315 Page 2 of 2 Printed:05/01/2014 11:22:59AM COMMONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript Civil COUNTY'OF CUMBERLAND Case Mag. Dist. No: MDJ-09-1-02 Capital One Bank (Usa) Na MDJ Name: Honorable Elizabeth S. Beckley V. Address: 1901 State Street Keith L Smith Camp Hill, PA 17011 Telephone: 717-761-0583 Capital One Bank(Usa) Na Docket No: MJ-09102-CV-0000225-2009 Attn: C/O Paul J Klemm Esq Case Filed. 7/8/2009 425 Eagle Rock Ave Roseland, NJ 07068 Disposition Summary (cc-Cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-09102-CV-0000225-2009 Capital One Bank(Usa)Na Keith L Smith Default Judgment for Plaintiff 09/01/2009 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank(Usa)Na $0.00 $0.00 $0.00 Keith L Smith $0.00 $1,516.84 $1,516.84 Judgment Finding (*Post Judgment) Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,413.14 $1,413.14 Costs $0.00 $103.70 $103.70 Grand Total: $1,516.84 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. q/1/09 ��1115141 . t" Date gi rial D' t Z Judge w . certify that this is a true and correct copy of the rec r o a procee rags cont m e lu j/ Date sterial istri t Judge MDJS 315 Page 1 of 2 Printed:05/01/2014 11:22:59AM Capital One Bank (Usa) Na Docket No.: MJ-09102-CV-0000225-2009 v. Keith L Smith Participant List Plaintiff(s) Capital One Bank(Usa) Na Attn: C/O Paul J Klemm Esq 425 Eagle Rock Ave Roseland, NJ 07068 Defendant(s) Keith L Smith 512 Poplar Church Rd Camp Hill, PA 17011-1832 Complainant's Attorney(s) Paul John Klemm, Esq. Nudelman Nudelman&Ziering 425 Eagle Rock Ave Roseland, NJ 07068 MDJS 315 Page 2 of 2 Printed:05/01/2014 11:22:59AM COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION COUNTY OF: CUMBERLAND HEARING NOTICE Mag.Dist,No.: PLAINTIFF: NAME and ADDRESS 09-1-02 FCAPITAL ONE BANK (USA) NA MDJ Name: Hon. 425 EAGLE ROCK AVE RONALD J. HORIIER ROSELAND, NJ 07068 Address: 1901 STATE ST L CAMP HILL, PA J VS. DEFENDANT: NAME and ADDRESS Telephone: (717 ) 761-0583 17 011 rSMI TH, KEITH L 512 POPLAR CHURCH RD ATTORNEY FOR PLAINTIFF CAMP HILL, PA 17011-1832 PAUL J. KLEM6S L J 425 EAGLE ROCK AVE Docket No.: CV-0000225-09 ROSELAND, NJ 07068 Date Filed: 7/08/09 A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 8/18/09 Place: DISTRICT COURT 09-1-02 1901 STATE ST Time: 1:30 PM CAMP HILL, PA 17011 717-761-0583 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: 7/08/09 10:48:09 AN AOPC 308B-05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Magisterial District Number: IPCAINTIFF: NAME and ADDRESS 09-1-02 (CAPITAL ONE BANK(USA), N.A. c/o Paul J. Klemm, Esquire MDJ Name,Hon. c/o Nudelman &Ziering, P.C. Robert V. Manlove X425 Eagle Rock Ave., Roseland, NJ 07068 _J Address: vs. 1901 State Street fdEFENDANT: NAME and ADDRESS KEITH L SMITH, Camp Hill, PA 17011 512 POPLAR CHURCH RD Telephone: X1AMP HILL PA 17011-1832 717/761-0583 Docket No.: 'a 35-19 Date Filed: AMOUNT DATE PAID FILING COSTS $ 7/. 0`0 7 1 POSTAGE $ SERVICE COSTS $ CONSTABLE ED. $ TOTAL $81.00 7 S7 (�1 Pa.R,C.P.D.J. No.206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT:The above named plaintiffs)asks judgment against you for$ 1 413.14 together with costs upon the following claim(Civil fines must include 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 5178052220677492. Defendant owes Plaintiff the principal amount of$1,020.22, interest of$225.52,and attorneys fees of. 5167.40. 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 and corr best of my knowledge, information,and belief. This statement is made subject to the penalties of Section 4904 a Crimes ode (18 PA. C.S.§4904) related to unsworn falsification to authorities. ( ure 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 30BA-05/NN47391