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Home My WebLink About02-5171DICKINSON COLLEGE, : Plaintiff : MONIQUE WARREN, : Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in xvfiting with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other fights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FiND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Attorney I.D. No. 8732 Ten East High Street Carlisle, PA 17013 (717) 243-3341 WILLIAMS & OTTO Attorneys for Plaintiff Date: October 24, 2002 DICKINSON COLLEGE, Plaintiff V. MONIQUE WARREN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. o - .r ? t C%. 't CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED COMPLAINT AND NOW, comes the Plaintiff Dickinson College by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: 1. Plaintiff is Dickinson College, a Pennsylvania educational institution and nonprofit corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Monique Warren is an adult individual residing at 3611 Brookridge Terrace, Harrisburg, Dauphin County, PA 17109. 3. Defendant is currently or was recently enrolled as a student at Plaintiff,s educational institution, Dickinson College. 4. Defendant mutually contracted with Plaintiff to pay tuition, dining service fees and other educational expenses as part of Plaintiff's promise to provide educational services and teaching to Defendant for said payment. 5. Defendant has failed to pay Plaintiff in full as mutually agreed and contracted. A copy of Defendant's student account is attached hereto as Exhibit "A" and is incorporated herein by reference as if fully set forth. 6. The outstanding balance due and payable by Defendant to Plaintiffis $2,979.98. See Exhibit "A" attached hereto. 7. The outstanding balance of $2,979.98 represents the total and actual overdue value of the services provided to the Defendant by Plaintiff for which Defendant has yet to pay. COUNTI BREACH OF CONTRACT 8. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 7 of this Complaint. 9. Plaintiff has fulfilled, performed and complied with all obligations and conditions of its agreement and contract for services with Defendant. 10. Defendant has breached the expressed and implied obligations, conditions and terms of agreement of Defendant's contract with Plaintiff to pay the amounts stated heroin. See Exhibit "A" attached hereto. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $2,979.98, an amount within the limits set forth for compulsory arbitration in Cumberland County, Pennsylvania. COUNT II QUANTUM MERUIT 11. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 10 of this Complaint. 12. Defendant is liable to Plaintiff and/or has been unjustly enriched in the amount of $2,979.98. WHEREFORE, Plaintiffdemandsjudgment against Defendant in the amount of $2,979.98, an amount within the limits set forth for compulsory arbitration in Cumberland County, Pennsylvania. M~ARTSON DEaF ~]]cLIAMS & OTTO By R. Galloway, E~ufre I.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: October 24, 2002 Attorneys for Plaintiff Exhibit A EXHIBIT "A" VERIFICATION I, THOMAS MEYER, Assistant Treasurer of Dickinson College, acknowledge that I have the authority to execute this Verification on behalf of Dickinson College and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of I8 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dated: October 24, 2002 Dickinson College Tho~ ~ Assistant Treasurer of Dickinson College ~ECEIVEL OCT 8 8 2002 ~4D~ir F: \FILES~DATAFILE~Dickinson Coll~t doc~33-pm 1/td¢ Created: 10/10/0203:06:13 PM 7619c 33 DICKINSON COLLEGE, Plaintiff V. MONIQUE WARREN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5171 CIVIL ACTION-LAW : : JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the attached Complaint against Monique Warren, 1619 Naudain Street, Harrisburg, Dauphin County, 17104, in the above captioned action and forward same to the Sheriff for service. MARTSON, DEARDORFF, WILLIAMS & OTTO B avid R. Gall6'~a~,Esquire Attorney I.D. No. 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: November 18, 2002 DICKINSON COLLEGE, Plaintiff MONIQUE WARREN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Date: October 24, 2002 MARTSON, DEARDORFF, WILLIAMS & OTTO BYDavid R.~~, ~§~'"- /f) ~ Attorney I.D. No. 87326 ~/ Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ' NO. · CIVIL ACTION-LAW MONIQUE WARREN, : Defendant · JURY TRIAL OF TWELVE DEMANDED COMPLAINT AND NOW, comes the PlaintiffDickinson College by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: l. Plaintiff is Dickinson College, a Pennsylvania educational institution and nonprofit corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Monique Warren is an adult individual residing at 3611 Brookridge Terrace, Harrisburg, Dauphin County, PA 17109. 3. Defendant is currently or was recently enrolled as a student at Plaintiff's educational institution, Dickinson College. 4. Defendant mutually contracted with Plaintiff to pay tuition, dining service fees and other educational expenses as part of Plaintiff's promise to provide educational services and teaching to Defendant for said payment. 5. Defendant has failed to pay Plaintiff in full as mutually agreed and contracted. A copy of Defendant's student account is attached hereto as Exhibit "A" and is incorporated herein by reference as if fully set forth. 6. The outstanding balance due and payable by Defendant to Plaintiff is $2,979.98. See Exhibit "A" attached hereto. 7. The outstanding balance of $2,979.98 represents the total and actual overdue value of the services provided to the Defendant by Plaintiff for which Defendant has yet to pay. COUNT I BREACH OF CONTRACT 8. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 7 of this Complaint. 9. Plaintiff has fnlfilled, performed and complied with all obligations and conditions of its agreement and contract for services with Defendant. 10. Defendant has breached the expressed and implied obligations, conditions and terms of agreement of Defendant's contract with Plaintiff to pay the amounts stated herein. See Exhibit "A" attached hereto. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $2,979.98, an amount within the limits set forth for compulsory arbitration in Cumberland County, Pennsylvania. COUNT II QUANTUM MERUIT 11. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 10 of this Complaint. 12. Defendant is liable to Plaintiff and/or has been unjustly enriched in the amount of $2,979.98. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $2,979.98, an amount within the limits set forth for compulsory arbitration in Cumberland County, Pennsylvania. MARTSON DEA~,, ORFF VOLLIAMS By iD. aDv. iNd oR. 8 .'~ ~~ay' l~q'~7i~e Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 & OTTO Date: October 24, 2002 Attorneys for Plaintiff ~00 f'JO <::~ EXHIBIT "A" VERIFICATION I, THOMAS MEYER, Assistant Treasurer of Dickinson College, acknowledge that I have the authority to execute this Verification on behalf of Dickinson College and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dated: October 24, 2002 Dickinson College Th~ ~ Assistant Treasurer of Dickinson College SHERIFF'S RETURN - CASE NO: 2002-05171 P COMMONWEALTH OF PENNSYLVANIA: COI/NTY OF CUMBERLAND DICKINSON COLLEGE VS WARREN MONIQUE OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT WARREN MONIQUE but was unable to locate Her deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: He therefore Pennsylvania, in his bailiwick. County, to On November 7th , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co 29.25 .00 66.25 11/07/2002 MDW&O Sheriff of Cumberland County Sworn and subscribed to before me this ~ ~ A.D. Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania : DICKINSON COLLEGE vs County of Dauph~ : WARREN MONIQUE Sheriff' s Return No. 2476-T - -2002 OTHER COUNTY NO. 02 5171 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for WARREN MONIQUE the DEFENDANT named in the within NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOWND, October 30, 2002 NEED BETTER ADDRESS. NEED APARTMENT NUMBER NAME NOT ON DOORBELLS. Sworn and subscribed to before me this 31ST day of OCT~ER, 2002 -el' [ ti ' / PROTHONOTARY So Answers, Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $29.25 PD 10/30/2002 RCPT NO 171129 In The Court of Common Pleas of Cumberland County, Pennsylvania Dickinson Colleue VS. Monique Warren SERVE: same N0. 02 5171 civil Now, October 29, 2002 ,I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Shcrig of Cumberland County, PA Affidavit of Service Now~ within _, 20 , at o'clock __ M. served the 1/pon at by handing to and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-05171 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DICKINSON COLLEGE VS WARREN MONIQUE R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: WARREN MONIQUE but was unable to locate Her deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE in his bailiwick. He therefore County, Pennsylvania, to On December 5th , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff,s Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 25.50 .00 62.50 12/05/2002 MDW&O So answers · ~- -.f~%f--~:i~ ~. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this /$~ day of ~7~ ~ A.D. Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin : DICKSON COLLEGE v$ · WARREN MONIQUE Sheriff's Return No. 2676-T OTHER COUNTY NO. AND NOW:November 26, 2002 at COMPLAINT WARREN MONIQUE to DEF AT RES of the original COMPLAINT -2002 02 5174CIVIL 9:25AMserved the within upon by personally handing 1 true attested copy(les) and making known to him/her the contents thereof at 1619 NAUDAIN STREET HARRISBURG, PA 17104-0000 Sworn and subscribed to before me this 26TH day of NOVEMBER, 2002 PROTHONOTARy So Answers, Sheriff of Dauphin County, Pa. By Deputy ~h~i f{ Sheriff,s Costs: $25.50 PD 11/25/2002 RCPT NO 172294 HOPKINS In The Court of Common Pleas of Cumberland County, Pennsylvania Dickin~qon Colle§e VS. Monique Warren SERVE: s~ne No. 02 5171 civil Now, November 21, 2002 ., I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service SOWs within ., 20 ., at o'clock M. served the upon at by handing to and made known to copy of the original So answers, the contents thereof. Sheriff of County, PA Sworn and subscribed before me this __ day of ~, 20 COSTS SERVICE MILEAGE AFFIDAVIT DICKINSON COLLEGE, Plaintiff V. MONIQUE WARREN, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5171 CIVIL ACTION-LAW : : JURY TRIAL OF TWELVE DEMANDED TO: MONIQUE WARREN, DEFENDANT You are hereby notified that on , ~-1 ~/ 2003, the following Judgment has been entered against you in the above-captioned case: $2,979.98, plus interest and costs. Date: Prothonotary 1' ! I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Ms. Monique Warren 1619 Naudain Street Harrisburg, PA 17104 F\FILES\DATAFILE~Dickinson Collect doc/33pra2/tde C~eated 10/10/02 03 0613 PM Revised 01/20/03 034041 PM 7619c 33 DICKINSON COLLEGE, : Plaintiff : V. .. MONIQUE WARREN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5171 C1VIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant in the amount of $2,979.98, plus interest and costs of suit, as prayed for in the Complaint and for failure to file an Answer to Plaintiff's Complaint. I do hereby certify that a written notice of intention to file this Praecipe (in the form attached hereto) was mailed to the Defendant at the address indicated thereon, on January 2, 2003, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON DEARDORFF WILLIAMS & OTTO B D~vid R' ~3~all°~'~-~uir~ I.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: January 20, 2003 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff MONIQUE WARREN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5171 CIVIL ACTION - LAW JURY TRIAL OF TWELVE DEMANDED TO: MONIQUE WARREN NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU 1N THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MARTSON DEARDORFF~[glLLIAMS By ~'~2~O~ David R. Galloway, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 & OTTO Date: January 2, 2003 Attorneys for Plaintiff PS Form 3817, Mar. 1989 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Monique Warren 1619 Naudain Street Harrisburg, PA 17104 MARTSON DEARDORFF WILLIAMS & OTTO (._ Tficia D. Ecken~o~d -- 7 - ' - Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: January 20, 2003 DICKINSON COLLEGE, : Plaintiff : : MONIQUE WARREN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5171 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED TO: MONIQUE WARREN, DEFENDANT You are hereby notified that on '~z~ ~ d/ been entered against you in the above-captioned case: $2,979.98, plus interest and costs. 2003, the following Judgment has Date: ~ .2 ~'..2 ov_~ Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Ms. Monique Warren 1619 Naudain Street Harrisburg, PA 17104 F:\FILES\DATAFILE\Dickinson Collect doc\33 pra2/tde Created 10/10/02 03:06 13 pM Revised 01/20/03 034041 PM 7619c 33 DICKINSON COLLEGE, Plaintiff : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MONIQUE WARREN, Defendant NO. 02-5171 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant in the amount of $2,979.98, plus interest and costs of suit, as prayed for in the Complaint and for failure to file an Answer to Plaintiff's Complaint. I do hereby certify that a written notice of intention to file this Praecipe (in the form attached hereto) was mailed to the Defendant at the address indicated thereon, on January 2, 2003, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON DEARDORFF WILLIAMS & OTTO ' D'~vid R. ~:{~llo~_~u~r~ / I.D. No. 87326 ~ Ten East High Street ~ Carlisle, PA 17013-3093 (717) 243-3341 Date: January 20, 2003 Attorneys for Plaintiff DICKINSON COLLEGE, : Plaintiff : V. : MONIQUE WARREN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5171 CIVIL ACTION - LAW JURY TRIAL OF TWELVE DEMANDED TO: MONIQUE WARREN NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU 1N THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MARTSON DEARDO _RF~S & OTTO David R. Galloway, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: January 2, 2003 Attorneys for Plaintiff P~ATIONAL MAIL, DOES~-OT ' PS Form 381 7, Mar. 1989 '#u s ~P0:1991-o 282-404/2574f CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Monique Warren 1619 Naudain Street Harrisburg, PA 17104 MARTSON DEARDORFF WILLLAMS & OTTO ia D. EckenTroad - "] .... k Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: January 20, 2003